United States securities and exchange commission logo
November 1, 2022
Dana Russell
Chief Financial Officer
Vivint Smart Home, Inc.
4931 North 300 West
Provo , UT 84604
Re: Vivint Smart Home,
Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-38246
Dear Dana Russell:
We have reviewed your October 4, 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
September 22, 2022 letter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations.
Adjusted EBITDA, page 60
1. We note your response
to prior comment number 1. Please remove the adjustment
Consumer financing
fees from Adjusted EBITDA as your presentation substitutes an
individually tailored
revenue recognition and measurement method for that of GAAP.
Refer to Question
100.04 of the Non-GAAP Compliance and Disclosure Interpretations.
Dana Russell
FirstName LastNameDana
Vivint Smart Home, Inc. Russell
Comapany 1,
November NameVivint
2022 Smart Home, Inc.
November
Page 2 1, 2022 Page 2
FirstName LastName
You may contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at
202-551-
3307 if you have questions regarding comments on the financial statements and
related matters.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services