SEC Comment Letter 0000000000-23-002485 to NOVONIX Ltd (NVX, NVNXF) (CIK 0001859795) (NVX)
NOVONIX Ltd (NVX, NVNXF) (CIK 0001859795)
Date: March 14, 2023 · CIK: 0001859795 · Accession: 0000000000-23-002485
AI Filing Summary & Sentiment
File numbers found in text: 001-41208
Letter
United States securities and exchange commission logo March 14, 2023 Nicholas Liveris Chief Financial Officer Novonix Limited Level 38 71 Eagle Street Brisbane, QLD 4000 Australia Re:Novonix Limited Form 20-F for the Transition Period July 1, 2022 to December 31, 2022 Filed February 28, 2023 File No. 001-41208 Dear Nicholas Liveris: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-F for the Transition Period July 1, 2022 to December 31, 2022 Item 18. Financial Statements Notes to the consolidated financial statements Note 15 Financial Assets at Fair Value Through Profit or Loss, page F-38 1.We note your policy that the group subsequently measures all equity investments at fair value and that you have recorded a loss on equity investment securities at fair value through profit and loss for the twelve months ended June 30, 2022. It does not appear that there has been a change in fair value other than exchange difference during the six months ended December 31, 2022. Please tell us how you concluded that there was no change in fair value subsequent to June 30, 2022. Refer to paragraph 5.7.1 of IFRS 9.
FirstName LastNameNicholas Liveris Comapany NameNovonix Limited March 14, 2023 Page 2 FirstName LastName Nicholas Liveris Novonix Limited March 14, 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 Melissa Gilmore at (202) 551-3777 or Kevin Woody at (202) 551- 3629 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
March 14, 2023
Nicholas Liveris
Chief Financial Officer
Novonix Limited
Level 38
71 Eagle Street
Brisbane, QLD 4000 Australia
Re:Novonix Limited
Form 20-F for the Transition Period July 1, 2022 to December 31, 2022
Filed February 28, 2023
File No. 001-41208
Dear Nicholas Liveris:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-F for the Transition Period July 1, 2022 to December 31, 2022
Item 18. Financial Statements
Notes to the consolidated financial statements
Note 15 Financial Assets at Fair Value Through Profit or Loss, page F-38
1.We note your policy that the group subsequently measures all equity investments at fair
value and that you have recorded a loss on equity investment securities at fair value
through profit and loss for the twelve months ended June 30, 2022. It does not appear that
there has been a change in fair value other than exchange difference during the six months
ended December 31, 2022. Please tell us how you concluded that there was no change in
fair value subsequent to June 30, 2022. Refer to paragraph 5.7.1 of IFRS 9.
FirstName LastNameNicholas Liveris
Comapany NameNovonix Limited
March 14, 2023 Page 2
FirstName LastName
Nicholas Liveris
Novonix Limited
March 14, 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 Melissa Gilmore at (202) 551-3777 or Kevin Woody at (202) 551-
3629 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing