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April 20, 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
Response dated
April 14, 2023
File No. 001-38701
Dear Anshul Maheshwari:
We have reviewed your April 14, 2023 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
March 31, 2023 letter.
Form 10-K for the fiscal year ended December 31, 2022
Consolidated Financial Statements
Property and Equipment, net, page 88
1. We have reviewed your
response to prior comment 1 and have the following additional
comments:
As it relates to
any individual instruments that are added to an instrument tray that
has been previously
placed into service, please provide us an analysis on how you
determined these
additions should not be accounted for as "maintenance and repairs;"
Similarly, as it
relates to any replacement instrument trays that are replacing
instrument trays
significantly before the end of their useful lives, please provide us an
Anshul Maheshwari
SI-BONE, Inc.
April 20, 2023
Page 2
analysis on how you determined these replacement trays should not be
accounted for
as "maintenance and repairs;"
Please clarify for us in further detail the life cycle of an
instrument tray that is
returned to the company. For example, clarify whether these
instrument trays remain
intact or are disassembled into the individual instrument components;
Please tell us the number of instrument trays that were replaced in
2022 and the range
and average length of time these instrument trays were in service
before being
replaced;
Please tell us the number of instrument trays that were returned to
the company in
2022 and the range and average length length of time these instrument
trays were in
service before being returned; and
Please tell us the estimated useful life of your instrument trays.
You may contact Michael Fay at 202-551-3812 or Brian Cascio, Accounting
Branch
Chief, at 202-551-3676 if you have any questions.
Sincerely,
FirstName LastNameAnshul Maheshwari Division of
Corporation Finance
Office of Industrial
Applications and
Comapany NameSI-BONE, Inc.
Services
April 20, 2023 Page 2
cc: Michael Pisetsky, SVP & CLO
FirstName LastName