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United States securities and exchange commission logo
December 20, 2023
Julie Zeiler
Chief Financial Officer
IRobot Corporation
8 Crosby Drive
Bedford , MA 01730
Re: IRobot Corporation
Form 10-K for the
fiscal year ended December 31, 2022
Filed February 14,
2023
Response Letter
Dated September 8, 2023
File No. 001-36414
Dear Julie Zeiler:
We have reviewed your September 8, 2023 response to our comment
letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our August 8,
2023 letter.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Key Financial Metrics and Non-GAAP Financial Measures, page 32
1. We reviewed your
response to prior comment 1. We continue to believe IP litigation
expenses are normal,
recurring, cash operating expenses. Please revise future filing to not
exclude IP litigation
expenses from Non-GAAP financial measures in any current, future
or prior period
presented. Please refer to Questions 100.01 and 100.02 of the Division of
Corporation Finance s
Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
Julie Zeiler
FirstName LastNameJulie Zeiler
IRobot Corporation
Comapany20,
December NameIRobot
2023 Corporation
December
Page 2 20, 2023 Page 2
FirstName LastName
Please contact Ernest Greene at 202-551-3733 or Anne McConnell at
202-551-3709 with
any questions.
Sincerely,
Division of Corporation
Finance
Office of Manufacturing