United States securities and exchange commission logo
September 21, 2023
Andrew Puhala
Chief Financial Officer
Stabilis Solutions, Inc.
11750 Katy Freeway, Suite 900
Houston, TX 77079
Re: Stabilis Solutions,
Inc.
Form 10-K for the
Fiscal Year ended December 31, 2022
Filed March 9, 2023
File No. 001-40364
Dear Andrew Puhala:
We have reviewed your filing 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-K for the Fiscal Year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Recent Developments, page 29
1. We note your disclosure
explaining that in the third quarter of 2022, you received
authorization from the
Department of Energy to export up to 51.75 billion cubic feet of
domestically produced
LNG per year to all free trade and non-free trade countries,
including Asian,
European, and Latin American importing nations, although you did not
make any exports under
this approval during the 2022 fiscal year.
Please expand your
disclosure to clarify the relevance of the authorization to your
business plans and
address the guidance in Item 303(a) and (b)(2)(ii) of Regulation S-K,
which require that you
focus specifically on material events and uncertainties that are
reasonably likely to
cause reported financial information not to be necessarily indicative
of future operating
results, matters that are reasonably likely to have a material impact on
Andrew Puhala
FirstName LastNameAndrew Puhala
Stabilis Solutions, Inc.
Comapany 21,
September NameStabilis
2023 Solutions, Inc.
September
Page 2 21, 2023 Page 2
FirstName LastName
future operations, and trends or uncertainties that are reasonably
likely to have a material
impact on net sales or income from continuing operations.
For example, discuss any plans you have adopted to export LNG to
countries covered by
the authorization, timeframes for commencement of sales, volumes
expected to be sold,
the specific markets or regions involved, initiatives or steps you
have undertaken or that
will be required to expand your logistical capabilities, and the
extent of any sales
commitments you had entered into as of the end of the period covered
by the report.
Results of Operations
Revenue, page 31
2. We note your discussion and analysis pertaining to the increase in
revenues and the
increase in cost of revenues consist of four bullet points attributing
the change to the sale
of higher volumes, higher prices/inflationary pressures, and
additional projects, although
the extent of the change attributable to these various factors remains
unclear.
Please expand your disclosure to address the guidance in Item 303(b)
and (b)(2)(iii) of
Regulation S-K, which require that you indicate the extent to which
material changes in
net sales are attributable to changes in prices or to changes in the
volumes or amounts of
goods or services being sold, or to the introduction of new products
or services.
Please also quantify the volumes associated with each source of
revenue identified on
page 28 in a tabulation with comparative sales and volumetric details
for each revenue
source. Please differentiate between sales of production, sales of
purchased LNG,
delivery service fees, and the various other service revenues.
Please submit the revisions that you propose to address these
concerns.
Financial Statements
Note 3 - Revenue Recognition
Disaggregated Revenues, page 54
3. We note the revenue categories identified in your table of
disaggregated revenues on
page 54 (i.e. LNG Product, Rental, Service, Other) differ somewhat
from the sources
described on page 28, (i.e. LNG Production and Sales, Transportation
and Logistics
Services, Cryogenic Equipment Rental, Engineering and Field Support
Services).
Tell us how these various revenues sources compare and reconcile to
one another and
explain how any differences were considered in preparing disclosures
that you believe
would be responsive to the requirements in FASB ASC 606-10-50.
Please differentiate between sales of production, sales of purchased
LNG, and the various
services being provided, and submit any revisions that you propose to
more clearly
identify categories of revenue that depict how the nature, amount,
timing, and uncertainty
Andrew Puhala
Stabilis Solutions, Inc.
September 21, 2023
Page 3
of revenue and cash flows are affected by economic factors, as
required by FASB ASC
606-10-50-5, and reflective of the varying terms of your contractual
arrangements and
consistent with FASB ASC 606-10-55-89 through 55-91.
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 Mark Wojciechowski, Staff Accountant, at (202) 551-3759
or Lily
Dang, Staff Accountant, at (202) 551-3867 if you have any questions.
FirstName LastNameAndrew Puhala Sincerely,
Comapany NameStabilis Solutions, Inc.
Division of
Corporation Finance
September 21, 2023 Page 3 Office of Energy &
Transportation
FirstName LastName