View:
United States securities and exchange commission logo
April 23, 2024
Steven Gatoff
Chief Financial Officer
Inseego Corp.
9710 Scranton Road, Suite 200
San Diego, CA 92121
Re: Inseego Corp.
Form 10-K for the
Fiscal Year Ended December 31, 2023
Form 8-K filed
February 21, 2024
Response dated
April 17, 2024
File No. 001-38358
Dear Steven Gatoff:
We have reviewed your April 17, 2024 response to our comment
letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in
our April 9, 2024 letter.
Form 8-K filed on February 21, 2024
Exhibit 99.1
1. We have reviewed your
response to prior comment 2. It appears to us that managing
inventory levels is an
integral aspect of your business; as such, it continues to appear to us
your non-GAAP
adjustments for "inventory adjustment - E&O and contract manufacturer
liability" and
"write-off of capitalized inventory fees" represent normal operating
expenses necessary to
operate your business and are not consistent with the guidance in
Question 100.01 of the
Division of Corporation Finance's Compliance & Disclosure
Interpretations on
Non-GAAP Financial Measures. Please revise future filings to no
longer exclude these
adjustments from any non-GAAP performance measure.
Steven Gatoff
FirstName LastNameSteven Gatoff
Inseego Corp.
Comapany
April NameInseego Corp.
23, 2024
April 223, 2024 Page 2
Page
FirstName LastName
Please contact Jeff Gordon at 202-551-3866 or Anne McConnell at
202-551-3709 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation
Finance
Office of Manufacturing