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March 31, 2023
Anshul Maheshwari
Chief Financial Officer
SI-BONE, Inc.
471 El Camino Real, Suite 101
Santa Clara, CA 95050
Re: SI-BONE, Inc.
Form 10-K For the
fiscal year ended December 31, 2022
Filed March 2, 2023
File No. 001-38701
Dear Anshul Maheshwari:
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
Consolidated Financial Statements
Property and Equipment, net, page 88
1. We note references
throughout your filing to instruments used by surgeons to implant
your products. Please
address the following as it relates to these instruments:
Describe to us
your full accounting for these instruments including initial recognition,
replacement,
impairment, etc.;
Tell us how you
have considered the guidance in ASC 842;
Describe to us
where these instruments are physically located, and how they are
physically tracked;
Tell us the
amounts and classifications of the different types of instruments that are
recorded on your
balance sheets;
Describe to us
any contracts between you and the doctors and hospitals regarding
Anshul Maheshwari
SI-BONE, Inc.
March 31, 2023
Page 2
these instruments;
Describe to us the circumstances regarding the loss on sale and
disposal of property
and equipment referred to in your statements of cash flows;
Revise MD&A in future filings to include insight and analysis
regarding your future
cash investment in instruments; and
In future filings, provide an accounting policy related to
these instruments in the
notes to your financial statements. Please provide us your
proposed policy.
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 Michael Fay at 202-551-3812 or Brian Cascio, Accounting
Branch
Chief, at 202-551-3676 with any questions.
Sincerely,
FirstName LastNameAnshul Maheshwari
Division of
Corporation Finance
Comapany NameSI-BONE, Inc.
Office of
Industrial Applications and
March 31, 2023 Page 2 Services
FirstName LastName