United States securities and exchange commission logo
June 27, 2022
Robert Andersen
Chief Financial Officer
Xperi Holding Corporation
3025 Orchard Parkway
San Jose, California 95134
Re: Xperi Holding
Corporation
Form 10-K for the
fiscal year ended December 31, 2021
Filed February 24,
2022
Form 8-K
Filed May 9, 2022
Supplemental
response letter dated June 22, 2022
File No. 001-39304
Dear Mr. Andersen:
We have reviewed your June 22, 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
June 8, 2022 letter.
Form 8-K Furnished May 9, 2022
Exhibit 99.1 Earnings Release
GAAP to Non-GAAP Reconciliations, page 8
1. We have reviewed your
response to prior comment 3 including the calculation of the
adjustment. We note
your explanation as to the purpose for this adjustment, which you
describe as a cash tax
presentation. It appears this adjustment smooths out the annual and
quarterly provision for
(benefit from) income taxes against the actual income taxes paid,
which represents an
accrual to cash basis adjustment. Please note that Non-GAAP
measures that include
tailored recognition and measurement methods can not be presented
Robert Andersen
Xperi Holding Corporation
June 27, 2022
Page 2
in documents filed or furnished with us. Refer to Question No. 100.04
of the Staff's
Compliance & Disclosures Interpretations ("C&DIs") on Non-GAAP
Financial Measures,
updated April 4, 2018. Please revise accordingly.
You may contact Beverly Singleton at (202) 551-3328 or Melissa Gilmore at
(202) 551-
3777 with any other questions.
FirstName LastNameRobert Andersen Sincerely,
Comapany NameXperi Holding Corporation
Division of
Corporation Finance
June 27, 2022 Page 2 Office of
Manufacturing
FirstName LastName