July 1, 2024
Ashley Cordova
Chief Financial Officer
NovoCure Ltd
1550 Liberty Ridge Drive
Wayne, PA
United States
Re: NovoCure Ltd
Dear Ashley Cordova:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).
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.
Form 10-K filed February 22, 2024
Note 13: Revenue Recognition, page 94
1. We note your presentation of revenue disaggregated by geographic region
as presented in
Note 13. Please tell us what consideration you gave to presenting
product revenue
disclosures as required by ASC 280-10-50-40. Additionally, refer to the
guidance and
examples in ASC 606-10-55-89 through 55-91 and explain to us the
consideration you
gave to presenting disaggregated revenue, such as by type of customer or
major product
category.
In closing, 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.
Please contact Tayyaba Shafique at 202-706-8224 or Terence O'Brien at
202-551-3355
with any questions.
July 1, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services