United States securities and exchange commission logo
May 3, 2021
J. Todd Koning
Executive Vice President and Chief Financial Officer
Alphatec Holdings, Inc.
5818 El Camino Real
Carlsbad, CA 92008
Re: Alphatec Holdings,
Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed March 5, 2021
File No. 000-52024
Dear Mr. Koning:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In 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, 2020
Item 9A. Controls and Procedures
Management's Report on Internal Control over Financial Reporting, page
55
1. Please ensure that in
future filings you clearly provide the conclusion reached upon
management's evaluation
and assessment of your internal control over financial reporting
as defined in Rules
13a-15(f) and 15d-15(f) of the Exchange Act. In this regard, please
explicitly state
whether such controls are effective or not effective. Please also identify
the version of the COSO
framework you used in your evaluation of the company's internal
control over financial
reporting.
J. Todd Koning
FirstName LastNameJ.
Alphatec Holdings, Inc.Todd Koning
Comapany
May 3, 2021NameAlphatec Holdings, Inc.
May 3,
Page 2 2021 Page 2
FirstName LastName
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-15
2. Your disclosure here and within your Critical Accounting Polices and
Estimates on page
51 primarily explains the general accounting model for revenue
recognition under ASC
606. In future filings, please revise your disclosures to explain how
you measure and
recognize revenue for your various types of contracts with customers
so that the disclosure
is specific to you and includes all of the disclosures required by ASC
606-10-50. In this
regard, please disclose significant payment terms, whether your
contracts include any
forms of variable consideration and how this is measured, and whether
your contracts
contain any additional performance obligations other than the sale of
spinal surgery
implants and products (i.e. service obligations). In making revisions
to your Critical
Accounting Policies and Estimates disclosure on page 51, please
include the significant
judgments and estimates involved in your accounting for contracts with
customers.
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 Ibolya Ignat at (202) 551-3636 or Angela Connell at (202)
551-
3426 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences