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SEC Comment Letter 0000000000-24-004301 to Lucid Group, Inc. (LCID) (CIK 0001811210) (LCID)

Lucid Group, Inc. (LCID) (CIK 0001811210)
Date: April 19, 2024 · CIK: 0001811210 · Accession: 0000000000-24-004301

AI Filing Summary & Sentiment

File numbers found in text: 001-39408

Date
April 19, 2024
Author
Not clearly detected
Form
UPLOAD
Company
Lucid Group, Inc. (LCID) (CIK 0001811210)

Letter

United States securities and exchange commission logo April 19, 2024 Gagan Dhingra Interim Chief Financial Officer Lucid Group, Inc. 7373 Gateway Boulevard Newark, CA 94560 Re:Lucid Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Filed February 27, 2024 File No. 001-39408 Dear Gagan Dhingra: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Cost of Revenue, page 77 1.Please tell us and expand your disclosures to provide additional insight for the increase in inventory and firm purchase commitments write-downs in 2023. Additionally, expand your critical accounting policy disclosures to identify the material assumptions you used in determining the allowance for excess or obsolete inventory, including more details of how you develop certain assumptions such as current and future demand forecasts. Note 2 - Summary of Significant Accounting Policies Segment Reporting, page 98 2.Please disclose revenues from external customers attributed to your country of domicile and attributed to all foreign countries in total from which you derive revenues in future filings. In addition, disclose long-lived assets located in your country of domicile and located in all foreign countries in total in which you hold assets. Also disclose the amount

FirstName LastNameGagan Dhingra Comapany NameLucid Group, Inc. April 19, 2024 Page 2 FirstName LastName Gagan Dhingra Lucid Group, Inc. April 19, 2024 Page 2 of revenues from external customers attributed to and the amount of long-lived assets in an individual foreign country, if material. Refer to ASC 280-10-50-41. Revenue from Contracts with Customers, page 101 3.Please tell us whether the revenue recognition policies disclosed for vehicle sales without Residual Value Guarantee apply to vehicles sales under the EV Purchase Agreement. If different, please disclose in future filings the revenue recognition policies applied to vehicle sales under the EV Purchase Agreement. Note 20 - Related Party Transactions, page 129 4.We note you disclosed various related party transactions. Please identify on the face of your consolidated balance sheets, consolidated statements of operations and comprehensive loss, and consolidated statements of cash flows the amounts of all related party transactions and balances in future filings pursuant to Rule 4-08(k) of Regulation S- X. 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. Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at 202-551-3777 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing

Show Raw Text
United States securities and exchange commission logo
April 19, 2024
Gagan Dhingra
Interim Chief Financial Officer
Lucid Group, Inc.
7373 Gateway Boulevard
Newark, CA 94560
Re:Lucid Group, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed February 27, 2024
File No. 001-39408
Dear Gagan Dhingra:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Cost of Revenue, page 77
1.Please tell us and expand your disclosures to provide additional insight for the increase in
inventory and firm purchase commitments write-downs in 2023.  Additionally, expand
your critical accounting policy disclosures to identify the material assumptions you used
in determining the allowance for excess or obsolete inventory, including more details
of how you develop certain assumptions such as current and future demand forecasts.
Note 2 - Summary of Significant Accounting Policies
Segment Reporting, page 98
2.Please disclose revenues from external customers attributed to your country of domicile
and attributed to all foreign countries in total from which you derive revenues in future
filings.  In addition, disclose long-lived assets located in your country of domicile and
located in all foreign countries in total in which you hold assets.  Also disclose the amount

 FirstName LastNameGagan Dhingra
 Comapany NameLucid Group, Inc.
 April 19, 2024 Page 2
 FirstName LastName
Gagan Dhingra
Lucid Group, Inc.
April 19, 2024
Page 2
of revenues from external customers attributed to and the amount of long-lived assets in
an individual foreign country, if material.  Refer to ASC 280-10-50-41.
Revenue from Contracts with Customers, page 101
3.Please tell us whether the revenue recognition policies disclosed for vehicle sales without
Residual Value Guarantee apply to vehicles sales under the EV Purchase Agreement.  If
different, please disclose in future filings the revenue recognition policies applied to
vehicle sales under the EV Purchase Agreement.
Note 20 - Related Party Transactions, page 129
4.We note you disclosed various related party transactions.  Please identify on the face of
your consolidated balance sheets, consolidated statements of operations and
comprehensive loss, and consolidated statements of cash flows the amounts of all related
party transactions and balances in future filings pursuant to Rule 4-08(k) of Regulation S-
X.
            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.
            Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at 202-551-3777 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing