SRSEC Reporting Desk

SemiLEDs Corp (LEDS)

CIK 1333822 · EDGAR correspondence

DateCompanyTypeOutcomeIssues
2026-01-27SemiLEDs Corp (LEDS)SEC staff letterReview completed (no further comments)
2026-01-20SemiLEDs Corp (LEDS)Company responseAgreed to reviseASC 606: Principal vs. AgentASC 606: Revenue Recognition
2026-01-12SemiLEDs Corp (LEDS)SEC staff letter1 staff comment(s) issuedASC 606: Principal vs. AgentASC 606: Revenue Recognition

Comments & responses

2026-01-12 · Form 10-K for the fiscal year ended August 31, 2025 Filed November 28, 2025 · Comment 1 · Revenue Recognition, page 52 Agreed to revise
Staff comment: We note your new business initiative (i.e., buy-sell orders of equipment) has significantly impacted your revenues and cost of revenues. Please address the following items. • In future filings, expand your disclosure (here and within your critical accounting policies and estimates on page 33) to clearly discuss buy-sell orders of equipment and your related accounting policies, including but not limited to gross versus net accounting treatment. • Provide to us supplementally your assessment of ASC 606 in your determination of whether to present revenue on a gross or net basis. In this regard, ensure your response addresses principal versus agent considerations as discussed in ASC… letter →
Company response: addresses principal versus agent considerations as discussed in ASC 606-10-55-36 through 40. Response: We have expanded our disclosures in the Summary of Significant Accounting Policies - Revenue Recognition in footnote 2 to Notes to Unaudited Condensed Consolidated Financial Statements and in Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations - Critical Accounting Policies End estimates in our Form 10-Q for the first fiscal quarter ended November 30, 2025 filed on January 14, 2026, and will continue disclosing them plus the new language in brackets below in our future filings. We added the following disclosures: Gross Versus Net Revenue ASC 606… response letter →
ASC 606: Principal vs. AgentASC 606: Revenue Recognition

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