Correspondence 0001819848-25-000061 from Joby Aviation, Inc. (JOBY, JOBY-WT) (CIK 0001819848) (JOBY)
Joby Aviation, Inc. (JOBY, JOBY-WT) (CIK 0001819848)
Date: Jan. 14, 2025 · CIK: 0001819848 · Accession: 0001819848-25-000061
AI Filing Summary & Sentiment
File numbers found in text: 001-39524
Referenced dates: January 13, 2025
Letter
CONFIDENTIAL AND PROPRIETARY DELIVERY VIA SECURE FILE TRANSFER Ms. Mindy Hooker & Mr. Hugh West Division of Corporation Finance U.S. Securities & Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Joby Aviation, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 Response dated December 13, 2024 File No. 001-39524
Dear Ms. Hooker & Mr. West:
On behalf of Joby Aviation, Inc. (the “Company”), we are writing this letter in response to the comment (the “Comment”) received by the Company from the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) by letter dated January 13, 2025. Set forth below is the Company’s response to the Comment (the “Response”). For the Staff’s convenience, the Comment is set forth below in italics.
1.Please update the Company’s risk disclosures to generally describe (i) the Company’s analysis of its/its subsidiaries’ status under Section 3(a)(1)(C), Section 3(c)(12), and under Rule 3a-8 and (ii) the risks to the Company should it/its subsidiaries not be eligible to rely on such exemptions.
The Company respectfully acknowledges the Staff’s comment and advises the Staff that it will update the Company’s risk disclosures in its future filings with the U.S. Securities and Exchange Commission, to the extent applicable, including in the Company’s Form 10-K for the year ended December 31, 2024, to generally describe (i) the Company’s analysis of its/its subsidiaries’ status under Section 3(a)(1)(C), Section 3(c)(12), and under Rule 3a-8 and (ii) the risks to the Company should it/its subsidiaries not be eligible to rely on such exemptions.
January 14, 2025
Page 2
If you have any questions related to the above, please contact Ross McAloon by email at Ross.McAloon@lw.com or by telephone at (714) 755-8501.
Regards,
/s/ Ross McAloon
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CORRESP 1 filename1.htm Document 140 Scott Drive Menlo Park, California 94025 Tel: +1.650.328.4600 Fax: +1.650.463.2600 www.lw.com FIRM / AFFILIATE OFFICES Austin Beijing Boston Brussels Century City Chicago Dubai Düsseldorf Frankfurt Hamburg Hong Kong Houston London Los Angeles Madrid Milan Munich New York Orange County Paris Riyadh San Diego San Francisco Seoul Silicon Valley Singapore Tel Aviv Tokyo Washington, D.C. January 14, 2025 CONFIDENTIAL AND PROPRIETARY DELIVERY VIA SECURE FILE TRANSFER Ms. Mindy Hooker & Mr. Hugh West Division of Corporation Finance U.S. Securities & Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Joby Aviation, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 Response dated December 13, 2024 File No. 001-39524 Dear Ms. Hooker & Mr. West: On behalf of Joby Aviation, Inc. (the “Company”), we are writing this letter in response to the comment (the “Comment”) received by the Company from the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) by letter dated January 13, 2025. Set forth below is the Company’s response to the Comment (the “Response”). For the Staff’s convenience, the Comment is set forth below in italics. 1.Please update the Company’s risk disclosures to generally describe (i) the Company’s analysis of its/its subsidiaries’ status under Section 3(a)(1)(C), Section 3(c)(12), and under Rule 3a-8 and (ii) the risks to the Company should it/its subsidiaries not be eligible to rely on such exemptions. The Company respectfully acknowledges the Staff’s comment and advises the Staff that it will update the Company’s risk disclosures in its future filings with the U.S. Securities and Exchange Commission, to the extent applicable, including in the Company’s Form 10-K for the year ended December 31, 2024, to generally describe (i) the Company’s analysis of its/its subsidiaries’ status under Section 3(a)(1)(C), Section 3(c)(12), and under Rule 3a-8 and (ii) the risks to the Company should it/its subsidiaries not be eligible to rely on such exemptions. January 14, 2025 Page 2 If you have any questions related to the above, please contact Ross McAloon by email at Ross.McAloon@lw.com or by telephone at (714) 755-8501. Regards, /s/ Ross McAloon Ross McAloon of LATHAM & WATKINS LLP