SEC Comment Letter 0000000000-23-008695 to Adeia Inc. (ADEA) (CIK 0001803696) (ADEA)
Adeia Inc. (ADEA) (CIK 0001803696)
Date: Aug. 10, 2023 · CIK: 0001803696 · Accession: 0000000000-23-008695
AI Filing Summary & Sentiment
File numbers found in text: 001-39304
Letter
United States securities and exchange commission logo August 10, 2023 Keith Jones Chief Financial Officer Adeia Inc. 3025 Orchard Parkway San Jose, CA 95134 Re:Adeia Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed on March 1, 2023 File No. 001-39304 Dear Keith Jones: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 34 1.We note your discussion of revenue refers to changes in long-term license agreements as well as changes in non-recurring revenue. In light of the potential variability attributable to non-recurring revenues, revise to separately quantify and discuss recurring revenues and non-recurring revenues for each period presented. Please provide us with proposed future disclosures based on your December 31, 2022 results. Refer to Item 303(b)(2) of Regulation S-K.
FirstName LastNameKeith Jones Comapany NameAdeia Inc. August 10, 2023 Page 2 FirstName LastName Keith Jones Adeia Inc. August 10, 2023 Page 2 Consolidated Financial Statements Note 4 - Revenue, page F-14 2.Please tell us what consideration was given to providing revenue disaggregation disclosures based on the pattern of recognition, such as over-time and point in time, to depict the timing and uncertainty of revenues and cash flows. Clarify whether recurring and non-recurring revenues are the same pattern of recognition as over-time and point in time and if not please explain how they differ. Also, tell us your consideration of disaggregation based on the nature of or market vertical for licensing revenues. In this regard, we note that you discuss your media portfolio and semiconductor portfolio in recent earnings calls and presentations. As part of your response, please provide us with such revenue disaggregation information for the periods presented. Refer to ASC 606-10- 50-5 and ASC 606-10-55-89 through 55-91. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Joyce Sweeney, Senior Staff Accountant at (202) 551-3449 or Christine Dietz, Senior Staff Accountant at (202) 551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Kevin Tanji
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United States securities and exchange commission logo
August 10, 2023
Keith Jones
Chief Financial Officer
Adeia Inc.
3025 Orchard Parkway
San Jose, CA 95134
Re:Adeia Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed on March 1, 2023
File No. 001-39304
Dear Keith Jones:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 34
1.We note your discussion of revenue refers to changes in long-term license agreements as
well as changes in non-recurring revenue. In light of the potential variability attributable
to non-recurring revenues, revise to separately quantify and discuss recurring revenues
and non-recurring revenues for each period presented. Please provide us with proposed
future disclosures based on your December 31, 2022 results. Refer to Item 303(b)(2) of
Regulation S-K.
FirstName LastNameKeith Jones
Comapany NameAdeia Inc.
August 10, 2023 Page 2
FirstName LastName
Keith Jones
Adeia Inc.
August 10, 2023
Page 2
Consolidated Financial Statements
Note 4 - Revenue, page F-14
2.Please tell us what consideration was given to providing revenue disaggregation
disclosures based on the pattern of recognition, such as over-time and point in time, to
depict the timing and uncertainty of revenues and cash flows. Clarify whether recurring
and non-recurring revenues are the same pattern of recognition as over-time and point in
time and if not please explain how they differ. Also, tell us your consideration of
disaggregation based on the nature of or market vertical for licensing revenues. In this
regard, we note that you discuss your media portfolio and semiconductor portfolio in
recent earnings calls and presentations. As part of your response, please provide us with
such revenue disaggregation information for the periods presented. Refer to ASC 606-10-
50-5 and ASC 606-10-55-89 through 55-91.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Joyce Sweeney, Senior Staff Accountant at (202) 551-3449 or Christine
Dietz, Senior Staff Accountant at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Kevin Tanji