SRSEC Reporting Desk

SemiLEDs Corp (LEDS) – SEC staff letter

2026-01-12 · Re: Form 10-K for the fiscal year ended August 31, 2025 Filed November 28, 2025 · Accession 0000000000-26-000340 · 1 staff comment(s) issued

Company response(s): 2026-01-20

ASC 606: Principal vs. AgentASC 606: Revenue Recognition

2026-01-12 · Form 10-K for the fiscal year ended August 31, 2025 Filed November 28, 2025 · Comment 1 · Revenue Recognition, page 52 Agreed to revise
Staff comment: We note your new business initiative (i.e., buy-sell orders of equipment) has significantly impacted your revenues and cost of revenues. Please address the following items. • In future filings, expand your disclosure (here and within your critical accounting policies and estimates on page 33) to clearly discuss buy-sell orders of equipment and your related accounting policies, including but not limited to gross versus net accounting treatment. • Provide to us supplementally your assessment of ASC 606 in your determination of whether to present revenue on a gross or net basis. In this regard, ensure your response addresses principal versus agent considerations as discussed in ASC… letter →
Company response: addresses principal versus agent considerations as discussed in ASC 606-10-55-36 through 40. Response: We have expanded our disclosures in the Summary of Significant Accounting Policies - Revenue Recognition in footnote 2 to Notes to Unaudited Condensed Consolidated Financial Statements and in Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations - Critical Accounting Policies End estimates in our Form 10-Q for the first fiscal quarter ended November 30, 2025 filed on January 14, 2026, and will continue disclosing them plus the new language in brackets below in our future filings. We added the following disclosures: Gross Versus Net Revenue ASC 606… response letter →
ASC 606: Principal vs. AgentASC 606: Revenue Recognition

Full letter on EDGAR → · Filing index · All SemiLEDs Corp (LEDS) correspondence

ASC 606: Principal vs. Agent – what to check: For each arrangement, document who controls the good or service before transfer (ASC 606-10-55-37A/39 indicators) and state the gross vs. net conclusion and rationale in the revenue policy.

ASC 606: Revenue Recognition – what to check: Confirm each performance obligation, timing (point vs. over time) and significant judgments are disaggregated and explained, not boilerplate ASC 606 language.

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