SEC Comment Letter 0000000000-23-000307 to Butterfly Network, Inc. (BFLY, BFLY-WT) (CIK 0001804176) (BFLY)
Butterfly Network, Inc. (BFLY, BFLY-WT) (CIK 0001804176)
Date: Jan. 12, 2023 · CIK: 0001804176 · Accession: 0000000000-23-000307
AI Filing Summary & Sentiment
File numbers found in text: 001-39292
Letter
United States securities and exchange commission logo January 12, 2023 Todd Fruchterman Chief Executive Officer Butterfly Network, Inc. 1600 District Avenue Burlington, Massachusetts 01803 Re:Butterfly Network, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 28, 2022 Response Dated December 16, 2022 File No. 001-39292 Dear Todd Fruchterman : We have reviewed your response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2021 Management's Discussion and Analysis of Financial Conditions and Results of Operations Non-GAAP Financial Measures, page 73 1.We note your response to comment 1. We see from your response that you will remove the non-recurring categorization for losses on purchase commitments and inventory write- downs in future filings. Please explain to us your consideration of the guidance in Item 10(e)(1)(ii)(b) of Regulation S-K and Question 100.01 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures in determining why you believe these adjustments, which appear to be costs incurred in the ordinary course of your business, are appropriate.
FirstName LastNameTodd Fruchterman Comapany NameButterfly Network, Inc. January 12, 2023 Page 2 FirstName LastName Todd Fruchterman Butterfly Network, Inc. January 12, 2023 Page 2 You may contact Christie Wong at 202-551-3684 or Julie Sherman, Senior Accountant, at 202-551-3640 if you have any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
Show Raw Text
United States securities and exchange commission logo
January 12, 2023
Todd Fruchterman
Chief Executive Officer
Butterfly Network, Inc.
1600 District Avenue
Burlington, Massachusetts 01803
Re:Butterfly Network, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 28, 2022
Response Dated December 16, 2022
File No. 001-39292
Dear Todd Fruchterman :
We have reviewed your response to our comment letter and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Conditions and Results of Operations
Non-GAAP Financial Measures, page 73
1.We note your response to comment 1. We see from your response that you will remove
the non-recurring categorization for losses on purchase commitments and inventory write-
downs in future filings. Please explain to us your consideration of the guidance in Item
10(e)(1)(ii)(b) of Regulation S-K and Question 100.01 of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures in determining why you believe these
adjustments, which appear to be costs incurred in the ordinary course of your business, are
appropriate.
FirstName LastNameTodd Fruchterman
Comapany NameButterfly Network, Inc.
January 12, 2023 Page 2
FirstName LastName
Todd Fruchterman
Butterfly Network, Inc.
January 12, 2023
Page 2
You may contact Christie Wong at 202-551-3684 or Julie Sherman, Senior
Accountant, at 202-551-3640 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services