SEC Comment Letter 0000000000-23-005016 to SOPHiA GENETICS SA (SOPH)
SOPHiA GENETICS SA
Date: May 11, 2023 · CIK: 0001840706 · Accession: 0000000000-23-005016
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File numbers found in text: 001-40627
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United States securities and exchange commission logo
May 11, 2023
Ross Muken
Chief Financial Officer
SOPHiA GENETICS SA
185 Dartmouth Street Floor 5
Boston, MA 02116
Re:SOPHiA GENETICS SA
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed March 7, 2023
Form 6-K furnished May 9, 2023
File No. 001-40627
Dear Ross Muken:
We have limited our review of your filing to the financial statements and related
disclosures 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 6-K furnished May 9, 2023
Exhibit 99.3
Reconciliation of IFRS to Adjusted IFRS Statement of Profit and Loss, page 11
1.Your non-IFRS presentation appears to represent a full consolidated statement of profit
and loss. Please tell us why you believe your presentation is consistent with Question
102.10(a) through (c) of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures.
FirstName LastNameRoss Muken
Comapany NameSOPHiA GENETICS SA
May 11, 2023 Page 2
FirstName LastName
Ross Muken
SOPHiA GENETICS SA
May 11, 2023
Page 2
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.
You may contact Mary Mast at (202) 551-3613 or Frank Wyman at (202) 551-3660 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences