January 14, 2016
Ms. Amanda Ravitz
Assistant Director
Office of Electronics and Machinery
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: MoSys, Inc.
Form 10-K for the year ended December 31, 2014
Filed March 13, 2015
Form 10-Q for the quarter ended March 31, 2015
Filed May 11, 2015
File No. 000-32929
Dear Ms. Ravitz:
MoSys, Inc. (“we” or the “Company”) submits this letter in response to the comments from the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”), which were set forth in your letter dated December 31, 2015 (the “Letter”) regarding the above referenced documents.
Form 10-Q for Fiscal Quarter Ended March 31, 2015
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 16
Results of Operations, page 17
1. We note that product revenue decreased due to a lower volume of integrated circuit shipments. In future filings, please discuss any unusual or infrequent events that individually had a material impact on your results. We note for example, statements made in your earnings call suggesting that a customer in Japan may have discontinued its orders. Please refer to Item 303(a)(3)(i) of Regulation S-K.
In future filings, we will discuss any unusual or infrequent events or transactions or any significant economic changes that materially affected the amount of reported income from continuing operations, and, in each case, will indicate the extent to which income was so affected, as required by Item 303(a)(3)(i) of Regulation S-K.
In connection with responding to the Staff’s comments, MoSys, Inc. acknowledges that:
· The Company is responsible for the adequacy and accuracy of the disclosures in its filings;
· Staff comments or changes to disclosures in response to Staff comments do not foreclose the Securities and Exchange Commission from taking any action with respect to the filings; and
· The Company may not assert Staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or any person under the federal securities laws of the United States.
Sincerely, |
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/s/ James W. Sullivan |
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James W. Sullivan |
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Chief Financial Officer |
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MoSys, Inc. |
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