United States securities and exchange commission logo
January 30, 2024
Paul Kim
Chief Financial Officer
Fulgent Genetics, Inc.
4399 Santa Anita Avenue
El Monte, California 91731
Re: Fulgent Genetics,
Inc.
Form 10-K for
Fiscal Year Ended December 31, 2022
Form 10-Q for
Fiscal Quarter Ended September 30, 2023
Response dated
January 9, 2024
File No. 001-37894
Dear Paul Kim:
We have reviewed your January 9, 2024 response to our comment
letter and have the
following comments.
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 November 21, 2023
letter.
Form 10-K for Fiscal Year Ended December 31, 2022
Note 7. Reporting Segment and Geographic Information, page F-23
1. We note that you have
identified four different revenue streams for your products and
services offerings: (a)
Precision Diagnostics; (b) Anatomic Pathology; (c) Pharma
Services; and (d)
COVID-19. We further note that your CODM and other members of
management regularly
receive and review revenues for these four revenue streams,
budgets are created at
the revenue stream level, and questions and other commentary of
revenues and revenue
trends are generated at this level during your earnings conference
calls. As such, please
provide the disclosures for each of these four revenue streams
required by ASC
280-10-50-40.
Paul Kim
Fulgent Genetics, Inc.
January 30, 2024
Page 2
Form 10-Q for Fiscal Quarter Ended September 30, 2023
Note 14. Goodwill and Acquisition-Related Intangible Assets, page 18
2. We note your response to comment 2. Specifically, we note that you did
perform a
quantitative analysis of your reporting unit using the market approach
as of September 30,
2023 (i.e., step one for an interim impairment test). As such,
disclosure here or within
MD&A would provide investors with information about the qualitative
factors considered
that led you to perform the quantitative analysis and the results of
that analysis. In this
regard, we also refer you to comment 3 in our letter dated November 1,
2023, for
disclosures to provide to investors regarding testing goodwill for
impairment.
Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,
FirstName LastNamePaul Kim
Division of
Corporation Finance
Comapany NameFulgent Genetics, Inc.
Office of
Industrial Applications and
January 30, 2024 Page 2 Services
FirstName LastName