SEC – ‘UPLOAD’ from 4/21/22 re: Dexcom Inc. – ‘TEXT-EXTRACT’

On:  Thursday, 4/21/22, at 11:30am ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed   ·   Accession #:  0-22-4281

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Comment or Other Letter from the SEC   —   Delayed-Release

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                 PDF     29K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC - PDF's         2±     7K 
                Text                                                             

‘TEXT-EXTRACT’   —   Comment or Other Letter from the SEC – PDF’s Text

United States securities and exchange commission logo                           

April 21, 2022          

Kevin R. Sayer                                                    
President and Chief Executive Officer                             
DEXCOM, INC.                                                      
6340 Sequence Drive                                               
San Diego, California 92121                                       

                                                Re: DEXCOM, INC.
                                                         Form 10-K for the
Fiscal Year Ended December 31, 2021                                             
                                                         Filed on February
14, 2022                                                                        
                                                      Form 8-K Dated
February 10, 2022                                                               
                                                      Response Dated
March 29, 2022                                                                  
                                                          File No. 000-51222

Dear Mr. Sayer:                                                   

             We have reviewed your response to our comment letter and have the
following                                                                       
    comment. In our comment, we may ask you to provide us with information
so we may better                                                                
understand your disclosure.                                       

     Please respond to the comment 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                                                          
    comment applies to your facts and circumstances, please tell us why in
your response.                                                                  

                                                    After reviewing your
response to the comment, we may have additional comments.                       

Form 8-K Dated February 10, 2022                                  

  Table E. Itemized Reconciliation Between GAAP and Non-GAAP Financial
Measures, page 9                                                                

1.                                                   We appreciate the    
information provided to us in your response letter and during the               
                                                conference calls
related to comment one in our letter dated March 22, 2022. We believe           
                                                     that your adjustments
to exclude the non-cash collaborative research and development fee              
                                                       from non-GAAP operating
income, non-GAAP adjusted EBITDA, non-GAAP net                                  
                                                       income and non-GAAP net
income per share are inconsistent with Rule 100(b) of                           
                                                    Regulation G. Please
confirm to us that you will no longer include these adjustments in              
                                                      any non-GAAP financial
measure presented in accordance with Item 10(e) of Regulation                   
                                                    S-K or Regulation G.
Kevin R. Sayer                                                                
DEXCOM, INC.                                                                    
April 21, 2022                                                                  
Page 2                                                                          

You may contact Christie Wong at (202) 551-3684 or Kristin Lochhead,
Senior Staff                                                                    
Accountant, at (202) 551-3664 with any questions.                               

FirstName LastNameKevin R. Sayer                        Sincerely,              
Comapany NameDEXCOM, INC.                                                       
                                                       Division of Corporation
Finance                                                                         
April 21, 2022 Page 2                                   Office of Life Sciences 
FirstName LastName                                                              

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Filed on:		4/21/22		UPLOAD
		3/29/22		4,  CORRESP,  UPLOAD
		3/22/22		UPLOAD
		2/14/22		10-K,  4,  UPLOAD
		2/10/22		4,  8-K,  UPLOAD
		12/31/21		10-K,  SD,  UPLOAD
				List all Filings