SEC Comment Letter 0000000000-23-001452 to Butterfly Network, Inc. (BFLY, BFLY-WT) (CIK 0001804176) (BFLY)
Butterfly Network, Inc. (BFLY, BFLY-WT) (CIK 0001804176)
Date: Feb. 13, 2023 · CIK: 0001804176 · Accession: 0000000000-23-001452
AI Filing Summary & Sentiment
File numbers found in text: 001-39292
Referenced dates: January 12, 2023
Letter
United States securities and exchange commission logo February 13, 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 January 27, 2023 File No. 001-39292 Dear Todd Fruchterman : We have reviewed your January 27, 2023 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 this 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 the comment in our letter dated January 12, 2023. We continue to believe that your adjustments to exclude the losses on purchase commitments from non- GAAP adjusted gross profit and non-GAAP adjusted EBITDA is inconsistent with Question 100.01 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures and Item 10(e) of Regulation S-K. Please confirm to us that you will no longer include these adjustments in any non-GAAP financial measure presented.
FirstName LastNameTodd Fruchterman Comapany NameButterfly Network, Inc. February 13, 2023 Page 2 FirstName LastName Todd Fruchterman Butterfly Network, Inc. February 13, 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
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United States securities and exchange commission logo
February 13, 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 January 27, 2023
File No. 001-39292
Dear Todd Fruchterman :
We have reviewed your January 27, 2023 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 this 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 the comment in our letter dated January 12, 2023. We continue
to believe that your adjustments to exclude the losses on purchase commitments from non-
GAAP adjusted gross profit and non-GAAP adjusted EBITDA is inconsistent with
Question 100.01 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures and Item 10(e) of Regulation S-K. Please confirm to us that you will
no longer include these adjustments in any non-GAAP financial measure presented.
FirstName LastNameTodd Fruchterman
Comapany NameButterfly Network, Inc.
February 13, 2023 Page 2
FirstName LastName
Todd Fruchterman
Butterfly Network, Inc.
February 13, 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