SEC Comment Letter 0000000000-23-000066 to IDEX Biometrics ASA (CIK 0001824036)
IDEX Biometrics ASA (CIK 0001824036)
Date: Jan. 4, 2023 · CIK: 0001824036 · Accession: 0000000000-23-000066
AI Filing Summary & Sentiment
File numbers found in text: 001-39810
Letter
United States securities and exchange commission logo January 4, 2023 Eileen Wynne Chief Financial Officer IDEX Biometrics ASA Dronning Eufemias gate 16 NO-0191 Oslo, Norway Re:IDEX Biometrics ASA Form 20-F for the Fiscal Year Ended December 31, 2021 Filed April 29, 2022 File No. 001-39810 Dear Eileen Wynne: We have reviewed your September 8, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our August 24, 2022 letter. Form 20-F for the Fiscal Year Ended December 31, 2021 Consolidated Statements of Changes in Equity, page F-5 1.We note your response to our prior comment and have considered the additional information you provided to us during our call with you on November 8, 2022 to explain the nature and purpose of the Company’s reduction in share premium to offset against accumulated loss. However, we object to the Company’s reclassification of share premium against accumulated loss. Please amend your Form 20-F for the fiscal year ended December 31, 2021 to restate your financial statements for the fiscal years ended December 31, 2020 and 2021 accordingly. Alternatively, provide a materiality analysis to support your conclusion that the impact of the error is not material. 2.We note from your prior response that in order to be eligible for the SkatteFUNN government grant program you were required to meet certain equity ratio criteria. Please
FirstName LastNameEileen Wynne Comapany NameIDEX Biometrics ASA January 4, 2023 Page 2 FirstName LastName Eileen Wynne IDEX Biometrics ASA January 4, 2023 Page 2 tell us if a restatement of the reclassifications of share premium against accumulated deficit will impact your ability to receive or retain funds received under the grant program. Also, in light of your restatement of the reclassification of share premium against accumulated deficit, please provide risk factor disclosure regarding your ability to comply with the conditions of the government grant program SkatteFUNN, and your ability to retain previously received funds as well as recognize future SkatteFUNN receipts. We refer you to paragraph 7 of IAS 20.
3.In a related matter, please tell us your consideration of management’s assessment of the effectiveness of ICFR in light of the restatement. If no consideration will be given, please explain why. That is, please explain to us why you believe internal controls over financial reporting continue to be effective in light of the error and why no modifications to the disclosures contained management’s report, including any material changes made to ICFR, are required. You may contact Joseph Cascarano, Senior Staff Accountant, at (202) 551-3376 or Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
January 4, 2023
Eileen Wynne
Chief Financial Officer
IDEX Biometrics ASA
Dronning Eufemias gate 16
NO-0191 Oslo, Norway
Re:IDEX Biometrics ASA
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 29, 2022
File No. 001-39810
Dear Eileen Wynne:
We have reviewed your September 8, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
August 24, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Consolidated Statements of Changes in Equity, page F-5
1.We note your response to our prior comment and have considered the additional
information you provided to us during our call with you on November 8, 2022 to explain
the nature and purpose of the Company’s reduction in share premium to offset against
accumulated loss. However, we object to the Company’s reclassification of share
premium against accumulated loss. Please amend your Form 20-F for the fiscal year
ended December 31, 2021 to restate your financial statements for the fiscal years ended
December 31, 2020 and 2021 accordingly. Alternatively, provide a materiality analysis to
support your conclusion that the impact of the error is not material.
2.We note from your prior response that in order to be eligible for the SkatteFUNN
government grant program you were required to meet certain equity ratio criteria. Please
FirstName LastNameEileen Wynne
Comapany NameIDEX Biometrics ASA
January 4, 2023 Page 2
FirstName LastName
Eileen Wynne
IDEX Biometrics ASA
January 4, 2023
Page 2
tell us if a restatement of the reclassifications of share premium against accumulated
deficit will impact your ability to receive or retain funds received under the grant program.
Also, in light of your restatement of the reclassification of share premium against
accumulated deficit, please provide risk factor disclosure regarding your ability to comply
with the conditions of the government grant program SkatteFUNN, and your ability to
retain previously received funds as well as recognize future SkatteFUNN receipts. We
refer you to paragraph 7 of IAS 20.
3.In a related matter, please tell us your consideration of management’s assessment of the
effectiveness of ICFR in light of the restatement. If no consideration will be given, please
explain why. That is, please explain to us why you believe internal controls over financial
reporting continue to be effective in light of the error and why no modifications to the
disclosures contained management’s report, including any material changes made to
ICFR, are required.
You may contact Joseph Cascarano, Senior Staff Accountant, at (202) 551-3376 or
Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology