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United States securities and exchange commission logo
August 10, 2023
Keith Jones
Chief Financial Officer
Adeia Inc.
3025 Orchard Parkway
San Jose, CA 95134
Re: Adeia Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2022
Filed on March 1,
2023
File No. 001-39304
Dear Keith Jones:
We have limited our review of your filing to the financial
statements and related
disclosures 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
Results of Operations, page 34
1. We note your discussion
of revenue refers to changes in long-term license agreements as
well as changes in
non-recurring revenue. In light of the potential variability attributable
to non-recurring
revenues, revise to separately quantify and discuss recurring revenues
and non-recurring
revenues for each period presented. Please provide us with proposed
future disclosures
based on your December 31, 2022 results. Refer to Item 303(b)(2) of
Regulation S-K.
Keith Jones
FirstName
Adeia Inc. LastNameKeith Jones
Comapany
August 10, NameAdeia
2023 Inc.
August
Page 2 10, 2023 Page 2
FirstName LastName
Consolidated Financial Statements
Note 4 - Revenue, page F-14
2. Please tell us what consideration was given to providing revenue
disaggregation
disclosures based on the pattern of recognition, such as over-time and
point in time, to
depict the timing and uncertainty of revenues and cash flows. Clarify
whether recurring
and non-recurring revenues are the same pattern of recognition as
over-time and point in
time and if not please explain how they differ. Also, tell us your
consideration of
disaggregation based on the nature of or market vertical for licensing
revenues. In this
regard, we note that you discuss your media portfolio and
semiconductor portfolio in
recent earnings calls and presentations. As part of your response,
please provide us with
such revenue disaggregation information for the periods presented.
Refer to ASC 606-10-
50-5 and ASC 606-10-55-89 through 55-91.
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.
You may contact Joyce Sweeney, Senior Staff Accountant at (202)
551-3449 or Christine
Dietz, Senior Staff Accountant at (202) 551-3408 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Kevin Tanji