Revenue recognition (ASC 606)

We acknowledge the Staff’s comment and have evaluated whether we act as principal or agent in our carbon credit transactions under ASC 606‑10‑55‑36 through 55‑40. In most of our carbon credit sales, we conclude that we are the principal because we control the credits before they are transferred to the customer. Our assessment is based on the following indicators: · Control of the asset before transfer (ASC 606‑10‑55‑37): We obtain control of the credits either by (i) originating them through our project arrangements, or (ii) purchasing them from third parties and holding them in our registry accounts prior to sale. We have the ability to direct the use of the credits (e.g., to sell them to different customers) and obtain substantially all of the remaining benefits until they are transferred or retired for the customer. · Primary responsibility for fulfillment (ASC 606‑10‑55‑39(a)): We…

We acknowledge the Staff’s comment. We recognize that ASC 606‑10‑50‑8 through 50‑10 requires disclosure of the opening and closing balances of contract liabilities (deferred revenue), significant changes in those balances, and information about the timing of revenue recognition for remaining performance obligations. Below is a roll forward as requested. FY2025 (Year Ended May 31, 2025) Q2 FY2026 (Six Months Ended Nov 30, 2025) Opening balance $ - $ 3,864,080 Heidelberg deferred revenue $ 928,042 $ (928,042 ) DevvStream deferred revenue $ 2,936,038 $ - Other deferred revenue $ - $ 26,764 Currency translation $ - $ (47,901 ) Closing balance $ 3,864,080 $ 2,914,901 Current portion $ 3,864,080 $ 2,914,901 Noncurrent portion $ - $ - 5 In future Annual Reports on Form 10‑K and, where material, Quarterly Reports on Form 10‑Q, we will provide a roll forward of deferred revenue and related…

We acknowledge the Staff’s comment. We agree that our revenue should be disaggregated to depict how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors, as required by ASC 606‑10‑50‑5 and 55‑89 through 55‑91. In future Annual Reports on Form 10‑K and, where material, Quarterly Reports on Form 10‑Q, we will disaggregate revenue by type of good or service and, if relevant, by geographic region or market. We will also provide the required narrative discussion linking the disaggregated revenue to our segment information (if applicable) and to our revenue recognition policies. Form 10‑Q for the Quarter Ended November 30, 2025 6 Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations – Results of Operations – Unaudited Results for the Six Months Ended November 30, 2025 and 2024, page 23

We respectfully acknowledge the Staff’s comment and respond as follows. The Company disaggregated revenue by regulatory pathway (ANDA versus NDA) in prior periods because, historically, those categories reflected distinct economic characteristics, including differences in development risk, regulatory approval timelines, pricing, and margin profiles. However, the Company acknowledges that it paused further development of NDA products in 2021 and has not engaged in active commercial NDA-related business activities since that time. Accordingly, for the periods presented, revenue associated with NDA-related activities is zero, and the Company agrees that disaggregation by regulatory pathway no longer provides a meaningful depiction of how economic factors affect the nature, amount, timing, or uncertainty of revenue, as contemplated by ASC 606-10-50-5 and ASC 606-10-55-91. With a view toward…

The Trust confirms that the required disclosures will be included in future filings.

The Company respectfully acknowledges the Staff’s comment and confirms that the security transactions meet the criteria described in FASB ASC 946-320-25-2.

The Company respectfully acknowledges the Staff’s comment and advises the Staff as follows: Accounting for Pre-Acquisition Hardware Deliveries in Purchase Price Allocation Under U.S. GAAP, consistent with ASC 606, hardware and subscription services are identified as separate performance obligations. Hardware revenue is recognized at a point in time when control of the hardware transfers to the customer, while revenue related to subscription services is recognized over time as the services are provided. Accordingly, under U.S. GAAP, hardware revenue is recognized when control is transferred to the customer, with a related contract asset, rather than deferring revenue over a period. The Company accounted for hardware sales made by Fleet Complete prior to the acquisition date in the purchase price allocation under ASC 805. Specifically, hardware deliveries made by Fleet Complete prior to…

We respectfully acknowledge the Staff’s comment, and, in response to the comment, will expand our disclosure of Subscription Annual Recurring Revenue (“ARR”) and add disclosure of Subscription Net Dollar Retention to address the items raised, as set forth in our proposed responsive disclosures below. • Clarify what "on-demand" revenue is and how it differs from annualized contract value from subscription agreements. On-demand revenue represents billings during a quarter for consumption by customers of our subscription services above a minimum usage commitment amount. The annualized value of on-demand revenue is calculated by multiplying such billings during the quarter by four. In contrast, annualized contract value from subscription amounts represents the annualized recurring value of all active, non-cancelable subscription contracts with subscription terms of any length at the end of…

As stated in Item 9A of Form 10-K, during the year ended December 31, 2023, we identified a material weakness in our internal control over financial reporting related to the design and operating effectiveness of controls over revenue. This was in large part due to the lack of a current, comprehensive contract database. Without such a database, preparing the remaining performance obligations (RPO) disclosure would require significant manual effort. However, we do have the necessary data to comply, in all material respects, with ASC 606 in our financial statements and other disclosures. As stated in Item 9A of Form 10-K, we can confirm that there has been no restatement of prior period financial statements and no change to our previously released financial results as a result of this material weakness. The Company notes that ASC 606-10-50-14A(b) excludes from the RPO disclosure variable…

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages F-19 and F-72 to clarify that wholesale loan originators are not charged a technology fee. Blockchain Common Stock, page 238

The Company respectfully acknowledges the Staff’s comment and confirms that the amount of license revenue recognized from the term-license software subscriptions (including related maintenance revenue) is less than ten percent of total revenues and less than three percent if excluding maintenance revenue, therefore, the Company’s presentation of revenue complies with Rule 5-03(b)(1)(a) of Regulation S-X. Further, the Company has considered the guidance in ASC 606-10-50-1 in evaluating whether and how its disclosures should disaggregate revenues. This assessment requires judgment, depends on various entity-specific and industry-specific factors and is not subject to any one prescribed factor as the basis for disaggregation. The Company has evaluated the guidance in ASC 606-10-50-5 through 50-7 and the related implementation guidance in ASC 606-10-55-89 through 55-91 with respect to the…

The Company respectfully acknowledges the Staff’s comment and will update the Company’s disclosure beginning with the Company’s Form 10-Q for the fiscal quarter ended July 31, 2025 to disclose the percentage of its contracted but unsatisfied performance obligations expected to be recognized on a quantitative basis using the following time bands: next 12 months; 13-24 months; and thereafter (less than 10% as of July 31, 2025). Actual amounts and timing of revenue recognition may differ from these estimates largely due to contract renewals and modifications. For the Staff’s reference, an updated disclosure is attached hereto as Exhibit C as an example, for illustrative purposes only, of how the Company intends to expand its disclosure in future filings. * * * PagerDuty, Inc. requests that the information contained in this letter, identified by the mark "[***]", be treated as confidential…

In response to the Staff’s comment, the Company has revised the disclosure on page F-15 showing the disaggregation of the Company’s revenues. Contract Assets, page F-16

In response to the Staff’s comment, the Company has revised the disclosure on page F-17. 3. Specific Risks Concentration and credit risks (a) Major customers, page F-23

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages F-19 and F-71 to enhance disclosure of ecosystem fee terms. The Company further advises the Staff that the delayed implementation fees disclosed on pages 93 and 192 are separate from ecosystem fees and represent a one-time charge intended to recover its costs to onboard a Partner in the event a Partner decides not to use the Company’s platform within a short onboarding period. The Company considers these amounts immaterial to its financial statements as it does not ultimately charge implementation fees to Partners in most cases. Potential implementation fees totaled $— million, $— million, $0.1 million, and $— million from 0, 0, 3, and 0 Partners for the three and six months ended June 30, 2025 and the years ended December 31, 2024 and 2023, respectively, of which 0, 0, 3, and 0 Partners…

The Company respectfully acknowledges the Staff’s comment and notes that the omission of such disclosure under ASC 606 is related to our material weakness. After remediation efforts are completed on the data that underlies the remaining performance obligations disclosure amount, the Company will make the disclosure. Note 16 - Segment Information, page 110

The Company respectfully advises the Staff that it generates substantially all of its revenue from the fees it charges to facilitate purchase and sale transactions between buyers and sellers of tickets on the Company’s marketplace. As described in Amendment No. 1, the tickets sold through the Company’s platform can be categorized into two types: original issuance tickets (i.e., initial sale of tickets by a content rights holder) and secondary tickets (i.e., resale of tickets by an individual or professional seller). The Company refers to the sale of original issuance tickets through its marketplace as “direct issuance.” In accordance with the Accounting Standards Codification 606 – Revenue from Contracts with Customers (“ASC 606”), for any purchase and sale of tickets on its platform, the Company evaluates its contract with the seller of such tickets to determine whether the Company is…

The Company has revised pages ii, iii, 8, 9, 13, 84, 85, 91, 111, 122, 130, 131, 133, 134, 135, 139, F-12, F-19, F-36 and F-37 to help clarify what the Company means when it refers to “direct issuance” and how the Company generates revenue from the sale of original issuance tickets through its global ticketing marketplace. While StubHub and viagogo have been traditionally known as ticketing marketplaces for resellers, the Company is focused on expanding its market opportunity by attracting another type of seller to its platform—content rights holders. The discussion of “direct issuance” throughout Amendment No. 1 refers to any original issuance tickets sold through the Company’s marketplace, as opposed to any resale by an individual or professional seller. The Company has revised its disclosures to clarify that it does not have a separate direct issuance model or solution or different…

We have revised our disclosure to add that revenue recognized associated with trade-ins solely relates to end-user boat purchasers and not to boat manufactures or other wholesalers on page F-11. Note 18. Segment Information , page F-48

We respectfully acknowledge the Staff’s comment and appreciate the opportunity to further clarify our revenue presentation and related disclosures. In consideration of the Staff’s comment, in future filings, beginning with our Form 10-Q for the quarter ended June 30, 2025, we will revise our revenue presentation and disclosures as outlined below: 1. Revenue Disaggregation on the Face of the Financial Statements (Rule 5-03(b) of Regulation S-X) We will revise the presentation of revenues and cost of revenues on the face of our consolidated statements of operations to separately present: • Term software license revenue and related costs • Software-as-a-service (SaaS) revenue and related costs • Perpetual license revenue and related costs (which are currently presented separately and will continue to be) We also will include a subtotal labeled “Total Subscription” that combines term…

We have revised the disclosure on pages F-55 and F-85 of Amendment No. 2 to include the typical expected length of Legacy Kodiak’s DaaS contracts. We advise the Staff that customers under a DaaS contract own the vehicles, and Legacy Kodiak provides autonomous driving capabilities to such customer-owned vehicles through the Kodiak Driver. Legacy Kodiak does not sell, license or lease vehicles to Atlas. We have clarified the disclosure in Amendment No. 2 in this regard to specify that the Kodiak Driver is used on customer-owned vehicles. We determined that the nature of Legacy Kodiak’s DaaS arrangements includes a single performance obligation to provide autonomous driving capabilities to customer-owned vehicles during the contract term based on the following considerations. We first assessed the promises in the applicable customer contract, which includes (i) the supply of the Kodiak…

In response to the Staff’s comment, the Company has revised the disclosure on the page F-41 of the Registration Statement. Fair Value Measurement, page F-41

The Company respectfully acknowledges the Staff’s comment and has deleted the disclosure regarding the cryptocurrency ecosystem on pages 2 and 92 of the Registration Statement. The Company has deleted the sentence “Further there have been limited precedents for the financial accounting of crypto assets and related valuation and revenue recognition, and no official guidance has been provided by the FASB or the SEC,” on page 36 of the Registration Statement.

In response to the Commission’s comment, the Company respectfully refers the Staff to the revised disclosure in the “Critical Accounting Estimates” subsection, which now includes an explanation that all estimates do not involve a significant level of estimation uncertainty and are not reasonably likely to have a significant impact on the financial results. The Company also respectfully clarifies the reasons as to why it no longer considers the estimates to be critical accounting estimates, specifically on credit loss on trade receivables, revenue recognition for construction in progress, the valuation of redeemable preference shares and the interest rate used to measure lease liabilities as follows: (i) Expected credit loss on trade receivables – The Group’s trade receivables are primarily involved counterparties with a low risk of default. The expected credit loss model applied is…

We respectively acknowledge the Staff’s comment and appreciate the opportunity to clarify our consideration of the guidance in ASC 606-10-50-5 and ASC 606-10-55-89 through 91 regarding the disaggregation of revenue between point-in-time and over-time recognition as it relates to our subscription revenues. In accordance with ASC 606-10-50-5, we understand that an entity is required to disaggregate revenue into categories that depict how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors. The extent of disaggregation depends on the specific facts and circumstances of the entity’s contracts with customers. As discussed in our response to Comment 3, our “Subscription” revenue line item includes both term-based license revenue (recognized at a point in time) and SaaS revenue (recognized over time). While these two components differ in the…

The Company respectfully acknowledges the Staff’s comment and provides the following responses to each part of the question above. • Quantify, for each period presented, the portion of revenues earned from product sales to UT on a cost plus margin basis as well as the portion of previously deferred revenue recognized for pre-production activities under the CSA. The Company acknowledges the comment and respectfully notes revenue recognized under the CSA for manufacturing services is comprised of sale of product, inclusive of sales to UT on a cost plus margin basis, recognition of previously deferred revenue, as well as reimbursements from other agreements for individual performance obligations which are accounted for separately. The portion of revenue related to each deliverable included in total CSA revenue for each period presented is as follows: Year Ended December 31, 2024 2023 2022…

We have revised the disclosure on page 36 of Amendment No. 1 to disclose the terms of Legacy Kodiak’s Master Services Agreement with Atlas (the “ Atlas MSA ”). We respectfully advise the Staff that we considered the footnote disclosure required under ASC 606-10-50-13 as it related to the Atlas MSA and determined that, as of December 31, 2024, it was immaterial quantitatively and qualitatively to the Legacy Kodiak financial statement footnotes because the remaining performance obligations would be performed over 4 years and the related future revenues for each annual period to December 2028 relative to Legacy Kodiak’s historical revenues for the year ended December 31, 2024 represented less than 10%. We have included the disclosures in the interim period as of March 31, 2025 on page F-96 of Amendment No. 1 as required by ASC 606-10-50-13. Further, we respectfully advise the Staff that…

A breakdown of each of these revenue streams is as follows: Ground autonomy solutions represented 89% of our revenues for both the years ended December 31, 2024 and 2023 and related to a single customer. Freight delivery represented 11% of our revenues for both the years ended December 31, 2024 and 2023 and related to 7 and 9 customers, respectively. Our DaaS revenues were not material for the years ended December 31, 2024 and 2023. 12 We have revised the disclosure on pages F-54 and F-55 of Amendment No. 1 to include a discussion of Legacy Kodiak’s revenue recognition policy for each of DaaS, freight delivery and ground autonomy solutions with reference to ASC 606-10-50-12. In particular, the revised disclosure includes information related to the performance obligations for each revenue stream, including the nature of Legacy Kodiak’s promises and how and when each is satisfied and…

We have revised the disclosure on pages F-54 and F-55 of Amendment No. 1 with reference to ASC 606-10-50-9 to include how the timing of satisfaction of performance obligations relates to the timing of payment and to remove the reference to milestones in respect of Legacy Kodiak’s billing practices. Note 17. Segment, page F-54

The Company’s cost of revenue for both freight brokerage and dedicated services is entirely comprised of the costs our carriers incur and invoice us to perform the service. In the case of freight brokerage services, this reflects their total costs for hauling the customers freight from origin to destination. In the case of dedicated capacity services, this reflects having the trucks available to haul freight for the customer and costs related to any freight movements. For both services, these costs include any accessorial charges carriers may incur such as loading or unloading, drayage, stoppage, fuel surcharges, border-crossing, packing materials, etc. The Company’s depreciation and amortization costs relate to the Company’s use over time of internally developed software, computer equipment, furniture, and our internet domain name. The Company considers all such costs to be operating…

The Company respectfully acknowledges the Staff’s comment and will revise its future filings to provide a separate revenue recognition policy for the Company’s continuing operations and to incorporate the Staff’s comments. The Company’s proposed disclosure is attached as Annex A. Exhibits

The Company respectfully acknowledges the Staff’s comment and will consider enhancing our tabular disclosures to include the amounts disclosed in non-tabular form and other material sub-components of our three revenue categories in future filings with the Commission. We have historically disaggregated revenue into the categories of transaction income, subscription revenue, and income from other services, as we believe these revenue categories best reflect how we view and manage our business. After consideration of providing further disaggregation by type of customer, we believe that our revenue disaggregation disclosures in the Annual Report meet the requirements of ASC 606-10-50-5 and 55-89 through 55-91; however, in the future we will consider adding additional dimensions of revenue disaggregation in future filings with the Commission if we believe that it would be meaningful to…

The Company acknowledges the Staff’s comment and provides the following responses to each item below. The Company has revised its revenue recognition policy under ASC 606 for the bitcoin mining business accordingly. The updated disclosure, included as an exhibit to this letter, will be reflected in the Form 10-Q for the quarter ending June 30, 2025, and in future filings in substantially the same form. ● Given that your mining pool contract can be terminated at any time by either party without penalty, tell us whether you believe the contract is continuously renewed, instead of renewed daily as you disclose. Refer to examples 1 and 2 of question 7 and question 8 of the FASB Revenue Recognition Implementation Guide Q&As. If so, tell us, and represent that you will revise your disclosure in future filings to discuss: o Your consideration as to whether the duration of your contracts is…

The Company respectfully acknowledges the Staff’s comment and clarifies that Collaboration and services revenue includes both the sale of product recognized in accordance with purchase orders for the supply of product and the recognition of previously deferred amounts for pre-production activities under the CSA, such as facility expansion and administrative services bundled under the Manufacturing Services performance obligation. Revenue is recognized for the supply of product at a point in time, once control is transferred to UT in accordance with the purchase orders from the customer which represents distinct contracts and performance obligations and previously deferred amounts related to the Manufacturing Services performance obligation are recognized as product is delivered over the CSA term based on measurement of progress. Please note the following disclosures presented in…

In our discussion under Variable Consideration within our Critical Accounting Estimates disclosure we disclosed that any differences between estimated settlements and final determinations are reflected as an increase or a reduction in revenue in the period when such final determinations are known. Historically these differences have been immaterial, and the Company has not had to go back and reassess the adjustments of future periods for past billing adjustments. In response to the Staff’s comment the Company intends to enhance the current disclosure as redlined below. Variable Consideration A significant portion of the Company’s revenues are derived, and the related receivables are due, from patients with commercial or government health insurance plans. Revenues are estimated using the portfolio approach 3 by third party payer type based upon historical rates of collection, the aging…

The Company respectfully advises the Staff that, during the preparation of the financial statements for the year ended December 31, 2023, it inadvertently disclosed the Managed Freight reportable segment revenue as being recognized upon completion of services, rather than proportionally as services were provided based on a percentage-of-completion method using the estimated time elapsed as of period end. The Company notes that there was no change in the methodology used to recognize revenue from 2022 to 2023. In updating the disclosure, the Company considered the guidance in ASC 250-10-45-23 and ASC 250-10-50-7 and concluded that the disclosure change was immaterial as there was no material difference in the amount of revenue recognized for the Managed Freight reportable segment between the two methods, thus the financial statements were materially correct. Division of Corporation…

The Company acknowledges the Staff’s comment and advises the Staff that it has it has considered the following: May 23, 2025 Page 2 As a Company-owned asset, the C2 driver undergoes routine maintenance after 90 hours of cumulative use or every two years, whichever occurs first. The associated costs are expensed as incurred. The Company does not charge a separate maintenance fee, nor is maintenance offered as a stand-alone service. At March 31, 2025, the C2 drivers have a net book value of approximately $42,000. The Identifying Distinct Goods: ASC 606-10-25-19: A good or service that is promised to a customer is distinct if both of the following criteria are met: a. The customer can benefit from the good or service either on its own or together with other resources that are readily available to the customer (that is, the good or service is capable of being distinct). b. The entity’s…

The Company acknowledges the Staff’s comment and advises the Staff that it has revised page F-12 and F-13 and F-44 and F-45 of Amendment No. 3 to address the Staff’s comment. If you have any questions, please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter. Sincerely, /s/ Michael J. Blankenship Michael J. Blankenship cc: Patrick NJ Schnegelsberg, Chief Executive Officer, Picard Medical, Inc. Exhibit A DRIVERS The SynCardia Total Artificial Heart (STAH) is an implantable device that replaces both sides of a failing heart and is powered by external driver units. SynCardia provides two driver units, each designed for different use environments. The STAH cannot operate with other driver types, and neither the STAH nor the driver units function independently. COMPANION 2 DRIVER The Companion 2 (C2) Driver powers the STAH during…

The Company acknowledges the Staff’s comment and advises the Staff that it believes its disclosures are consistent with the requirements of ASC 606. In accordance with ASC 606-10-50-5, the Company considered the level of revenue disaggregation that depicts how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors. The Company also evaluated the guidance in ASC 606-10-55-89 through 91, which suggests that the extent of disaggregated revenue information depends on the facts and circumstances of the underlying contracts with customers. The Company believes that disaggregating revenue by its three reportable segments provides meaningful information to investors, aligns with how management evaluates financial performance and allocates resources and meets the objective of ASC 606-10-50-5 as described above. The Company also advises the Staff…

The Company acknowledges the Staff’s Comment and responds as follows: • The contracted operator is compensated through a services arrangement that entitles them to retain an agreed portion of gross proceeds, net of equipment usage fees and shared costs. These amounts are classified as selling and marketing expenses. All other direct production costs are reported as cost of goods sold. • The Company has updated its disclosure on page 25 of Amendment No. 2 and in Note 6 to the financial statements to update the terms of the subscontractor agreement; and May 15, 2025 Page 8 • In arriving at that the determination that we are the principal pursuant to ASC 606- 10-55-36 through 55-40, we undertook the following analysis: The Company maintains ownership and control of the facility, assets, and customer relationships. Revenue from customer contracts is recognized by the Company in accordance…

The Company acknowledges the Staff’s comment and advises the Staff that it has revised page 64 of Amendment No. 2 to address the Staff’s comment. In addition, please also see our responses below for each of the bullet points listed in the comment above. May 9, 2025 Page 2 ● We identify that while the patient is the end user, our contracted customer is the Mechanical Circulatory Support (“MCS”) equipment management and distribution company. We further confirm that rental costs only include Freedom driver related costs, as we have the capability to segregate technician labor hours between drivers by work order. ● We have elaborated that the hospital is our customer. In reference with ASC 606, the Company considers that the sale of the TAH Kit is the sole performance obligation and the C2 driver, cart and caddy is equipment used in the hospital but is not separately rented nor sold. It is…

To address the Staff’s comment, the Company has revised the disclosure on pages 277 of the Amendment. The Company has also expanded its disclosure to clarify when performance obligations are satisfied, the timing of revenue recognition, and methods used for time-and-materials and fixed-fee contracts, consistent with ASC 606-10-50-18. The changes made in revenue recognition policy in the ‘Critical Accounting Policies and Estimates’ section will be incorporated in the significant accounting policies section of the financial statements going forward. Note 12. Long-Term Debt – Related party convertible notes payable at fair value, page F-54

GCI Liberty respectfully acknowledges the Staff’s comment. In response to the Staff’s comment, GCI Liberty has provided its analysis of the relevant accounting guidance below. GCI Liberty considered the guidance in ASC 460-10-15-7(k), which states that a sales incentive program in which an entity contractually guarantees to reacquire equipment at a customer’s request at specified time periods is not subject to the guidance in ASC 460 and shall evaluate such arrangements in accordance with ASC 606, specifically the guidance on repurchase agreements in paragraphs 606-10-55-66 through 55-78. In consideration of this guidance, GCI Liberty concluded it is consistent with the Upgrade Now Program because the program provides its customers with the ability to contractually require the Company to repurchase their handset at the customer’s request for a guaranteed price at specified time periods…

GCI Liberty respectfully acknowledges the Staff’s comment. In response to the Staff’s comment, GCI Liberty informs the Staff that revenue recognized at a point in time related to products sold is immaterial and represented less than 3.5% and less than 4.0% of total combined revenue for the years ended December 31, 2024 and 2023, respectively. Given the insignificance of revenue recognized at a point in time as compared to total combined revenue, disaggregating by timing of revenue recognition was concluded to not be relevant to the Company. In further support of its conclusions with respect to the disaggregation of revenue, GCI Liberty provides additional analysis below. 9 ASC 606-10-55-89 through 55-91 provides additional guidance for entities to consider when concluding on their disclosure of disaggregated revenue. In selecting the type of categories to use to disaggregate revenue,…

GCI Liberty respectfully acknowledges the Staff’s comment. In response to the Staff’s comment, GCI Liberty advises the Staff that substantially all of its consumer customers have month-to-month contracts and can cancel at any time without significant penalty. However, if a consumer customer were to cancel their service in the middle of a month, the service cancellation is not effective until month-end. With respect to GCI Liberty’s business customers, the most common contractual term ranges from one to five years. Business customer contracts can generally be cancelled at any time but there is usually an early termination fee that can range from the equivalent of one month of service up to the remaining contractual amount due under the contract. GCI Liberty advises the Staff that it has updated its disclosure to include the summary information provided in this paragraph. 10 The Company…

GCI Liberty respectfully acknowledges the Staff’s comment. In response to the Staff’s comment, GCI Liberty advises the Staff that its customers do not take possession of the products it sells before such products are delivered. Total combined revenue from product sales for the Company was less than 3.5% and less than 4% of total combined revenue for years ended December 31, 2024 and 2023, respectively. All of the Company’s product sales relate to the sale of mobile handset devices, tablets, streaming devices, wearables, and other accessories (e.g. cases for mobile handsets). Substantially all of GCI Liberty’s revenue recognized for all such products occurs after its customers take possession of the product. With respect to data arrangements, product sales relate to GCI Liberty’s streaming devices (e.g. Apple TV 4K or Amazon Fire TV Stick), which are immaterial to total combined revenue…

GCI Liberty respectfully acknowledges the Staff’s comment. In response to the Staff’s comment, GCI Liberty advises the Staff that its current and long-term deferred revenue amounts included in the combined balance sheets consists of deferred revenue associated with (i) contracts with customers, (ii) government assistance, and (iii) an immaterial other amount. As further discussed below, GCI Liberty discloses the amount of deferred revenue associated with contracts with customers on pages F-13 to F-14 of the financial statements and the amount of deferred revenue associated with government assistance on page F-14, such that the combination of the two disclosures reconciles within an immaterial amount to the amounts included in the combined balance sheets. For the Staff’s benefit, GCI Liberty has included a table below reconciling the deferred revenue amounts disclosed in the notes to the…

The Company respectfully acknowledges the Staff’s comment and will revise its disclosures in Note 2, Revenue Recognition in its future filings with the SEC to provide further clarity on its variable consideration and significant judgements in accordance with ASC 606-10-17 and 50-20. Both Progyny’s fertility and pharmacy benefits solutions include a single performance obligation, which is a stand-ready obligation that is a series of distinct days of service satisfied over the contract term. Progyny’s fertility and pharmacy benefits solutions contracts include both the following sources of consideration, which are variable: a per employee per month (‘‘PEPM”) administration fee (in most, but not all contracts) and a stated fixed rate per Smart Cycle or fertility drug dispensed, respectively. The PEPM administration fee, which although based on a fixed rate, is contingent upon the number of…

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it estimates credit losses, including its allowance for doubtful accounts, in accordance with ASC 326 based on the lifetime expected credit losses for receivables, aggregated on the basis of similar risk characteristics, which include the client and member receivable pools. The client pool primarily includes receivables with large self- insured employers and labor populations with at least 1,000 employees and the member pool represents receivables with individual members for their cost share (e.g. deductibles and coinsurance) associated with using the Company’s services. The Company recognizes an allowance for credit losses at the time its accounts receivable is recognized, including for current or not yet due amounts. The allowance is primarily based on the Company’s historical experience of losses for…

The Co-Registrants respectfully acknowledge the Staff’s comment and advise the Staff that the Co-Registrants have amended the disclosure on page F-33 of the Amended Registration Statement to include the requested information. GrabAGun has performed an analysis under ASC 606-10-55-39 to evaluate its role in transactions involving drop-ship sales arrangements. Based on the indicators of control outlined in the guidance, GrabAGun has determined that it acts as the principal in these transactions and, accordingly, recognizes revenue on a gross basis. Control of the specified good is maintained by GrabAGun throughout the transaction. GrabAGun bears responsibility for fulfilling the customer’s order because it directs the shipment of the firearm and other products to the customer’s selected Federal Firearms Licensee (“FFL”) location or other appropriate location. The third-party supplier is…

We respectfully acknowledge the Staff’s comment and advise the Staff that the Company had no material revenue arrangements reported on a net basis, and we have not identified matters involving significant judgment in our determination that revenue from contracts with customers should be reported on a gross basis. Likewise, we respectfully advise the Staff that the Company believes its disclosure in Note 12 – Revenues in the 10-K, complies with the disaggregated revenue disclosure requirements set forth in FASB ASC 606-10-50-5 and -55-89 through -55-91. 4 We note the Staff’s reference to the Company’s disclosure in Note 2 – Summary of Significant Accounting Policies (Revenue Recognition) in the 10-K that “ we assess whether we are the principal or the agent in the arrangement. Arrangements where we have concluded that we act as a principal are presented within our Consolidated Statements…

The Company respectfully acknowledges the Staff’s comment. The Company has evaluated the guidance in ASC 606-10-50-5 and the related implementation guidance in ASC 606-10-55-89 through 91 with respect to additional disclosures of disaggregated revenues, specifically ASC 606-10-50-5, which requires an entity to disaggregate revenue from contracts with customers into categories that depict how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors. The Company considered the examples of categories of disaggregated revenues in ASC 606-10-55-91. The Company’s business is organized around two reportable segments: Medical and Industrial. These segments align with the Company’s products and services offerings, regulatory differences between the two segments, sales organization, and economic cycles. The Company provides disaggregated revenue by…

We have updated the revenue recognition accounting policy on page F-72 to include the principal versus agent considerations for the specialized medical and aesthetic services provided under profit-sharing arrangements with the partners. Please refer below for the amendments: ‘‘For hair implant services, specialised medical and aesthetic services, the Group exercises control over the delivery of the service before it reaches the customer. Consequently, the Group is deemed a principal for these services and recognises revenue based on the total amount charged to the customer.’’ Financial Statements of Alp Life Sciences Inc., page F-116

In response to the Staff’s comment, we respectfully advise the Staff that disaggregated revenue by group of similar products and services is presented in page F-20 and F-44 as prescribed by ASC 280-10-50-40. As prescribed by ASC 606-10-55-91, when selecting the type of category (or categories) to use to disaggregate revenue, examples of categories that might be appropriate include, but are not limited to, all of the following:: a) Type of good or service (for example, major product lines) b) Geographical region (for example, country or region) c) Market or type of customer (for example, government and nongovernment customers) d) Type of contract (for example, fixed-price and time-and-materials contracts) e) Contract duration (for example, short-term and long-term contracts) f) Timing of transfer of goods or services (for example, revenue from goods or services transferred to customers…

The Company respectfully acknowledges the Staff’s comment. The Company has reviewed Question 7 of the FASB Revenue Recognition Implementation Q&As and concluded that the mining pool contracts align with Example 1 of such Question, where the contract can be terminated by each party at any time without compensating the other party for the termination, other than paying amounts due as a result of goods and services transferred up to the termination date. In future filings, the Company will revise its disclosures to reflect that the duration of the contract for accounting purposes is less than 24 hours because the contract continuously renews throughout the day. April 14, 2025 Page 3 • You disclose that you recognize revenue over the contract term as hashrate is provided. ASC 606-10-25-23 indicates that recognition occurs upon the transfer of control of the service. Tell us your…

The Company has added disclosure in the revenue recognition discussion in the financial statements about its contract liabilities that, for the Company, primarily represent consideration received from customers for hybrid corn seed in advance of fulfilling performance obligations. Additionally, there has been added a table showing the de-recognition of contract liability, customer prepayments and revenue recognized for the three fiscal years 2022-2024. Securities and Exchange Commission April 11, 2025 Page 5 General

We acknowledge the Staff’s comment. While we believe the Company’s current disaggregated revenue disclosure was appropriately developed after carefully considering the guidance in ASC 606-10-50-5, as well as ASC 606-10-55-89 through 55-91, in future filings, we intend to enhance our disclosure as discussed below. In historical filings, the Company considered and periodically evaluated the appropriate level of disaggregation into categories that depict how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors. As a result of this evaluation, we determined that more than one type of category disaggregation was needed. When considering the disaggregated revenue disclosure, the Company evaluates both company-specific and macroeconomic factors. Sales of instruments can be capital-intensive for buyers and more subject to specifically allocated…

The Company respectfully acknowledges the Staff’s comment and, in response to the Staff’s comment, in future filings, we will expand the disclosure as follows with additions in bold and underlined and deletions in strikethrough: NOTE 2. REVENUE, DEFERRED REVENUE AND DEFERRED COMMISSIONS Disaggregation of Revenue and Revenue Recognition Contracted not recognized revenue was approximately $2.1 billion as of July 31, 2024, of which we expect to recognize approximately 52% within over the next 12 months, approximately 38% over the subsequent 13-to-36 month period , and the remainder thereafter. Form 8-K furnished on February 26, 2025 Exhibit 99.1, page 7

The Co-Registrants acknowledge the Staff’s comment have revised the disclosure on pages 179 and 180 of the Amendment. The Co-Registrants confirm that APAC Joint Venture documents have not yet been finalized, and as such, the accounting is still pending executed documents. When considering if the $6 million consideration represents revenue form a customer or consideration from the sale of 60% interest in the JV management considered specific features of the transaction such as control being transferred. Management believes that only partial control is being transferred in this agreement and therefore, the APAC Joint Venture transactions would be scoped out of ASC 606. The license is being shared and partial control is being given but full control over the license is not being transferred. Accordingly, the income statement impact associated with the difference between consideration…

In response to the Staff’s comment, we have considered the following indicators outlined in paragraph 606-10-55-39 in accordance with ASC 606-10-55-317 through 319: ASC 606-10-55-317 and ASC 606-10-55-318A We operated the mobile app and WeChat Mini-Program to enable customers to purchase products from us, not from suppliers. The counterparty in the sales transaction is us, not the suppliers, as customers cannot access supplier information through the mobile app or WeChat. All the products listed on our mobile app and WeChat Mini-Program are offered by us. We determine what product information to be published on our mobile app and WeChat Mini-Program. Under the terms of our sales agreement with customers, we are responsible for fulfilling the promise to provide the specified goods. We are responsible for the acceptability of the goods. According to the acceptance terms of our sale…