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United States securities and exchange commission logo
February 3, 2023
Ran Daniel
Chief Financial Officer
Nano-X Imaging Ltd.
Communication Center
Neve Ilan , Israel 9085000
Re: Nano-X Imaging Ltd.
Form 20-F for
Fiscal Year Ended December 31, 2021
Filed May 2, 2022
Response Letter
Dated February 1, 2023
File No. 001-39461
Dear Ran Daniel:
We have reviewed your February 1, 2023 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 this 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 this comment, we may have
additional
comments. Unless we note otherwise, our reference to a prior comment are
to comments in our
January 18, 2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2021
Item 5. Operating and Financial Review and Prospects
E. Critical Accounting Estimates, page 90
1. We note your response
to comment 2. Regarding the draft disclosures provided, please
address the following:
Clarify that the
amount of goodwill assigned to the AI solutions reporting unit at the
interim testing
date was $51.2 million and that $14.3 million was recognized as an
impairment charged
based on the testing results.
Expand your
discussion of the discounted cash flow model used to estimate the fair
value of your AI
solutions reporting unit to state when you have assumed that the
business will be
generating material revenues, gross profit and positive operating
Ran Daniel
Nano-X Imaging Ltd.
February 3, 2023
Page 2
cash flows to support the remaining $36.9 million of goodwill as
of December 31,
2022.
You may contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355, if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,
FirstName LastNameRan Daniel
Division of
Corporation Finance
Comapany NameNano-X Imaging Ltd.
Office of
Industrial Applications and
February 3, 2023 Page 2 Services
FirstName LastName