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United States securities and exchange commission logo
November 29, 2021
Eric Lefkofsky
Chief Executive Officer
Tempus Labs, Inc.
600 West Chicago Avenue, Suite 510
Chicago, Illinois 60654
Re: Tempus Labs, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted on
October 28, 2021
CIK No. 0001717115
Dear Mr. Lefkofsky:
We have reviewed your amended draft registration statement and
have the following
additional comment. In our comment, we may ask you to provide us with
information so we
may better understand your disclosure.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to this
comment and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Consolidated Financial Statements
Revenue Recognition, page F-14
1. We note your responses
to prior comments 23 through 25. So that we may better
understand your
accounting for refreshes, please supplementally address the following:
Explain in greater
detail the nature of your performance obligations related to
refreshes,
including how they are defined and priced in your contracts with
customers, the
specific features and functionality refreshes provide, and the period of
time over which you
are required to provide refreshes.
Tell us how you
considered if these refreshes represent a stand-ready obligation to
provide future
products or services on a when-and-if-available basis.
Explain the
consequences, if any, if you do not provide refreshes to your customers.
Eric Lefkofsky
Tempus Labs, Inc.
November 29, 2021
Page 2
You may contact Lisa Etheredge, Senior Staff Accountant, at
(202)551-3424 or Robert
Littlepage, Accounting Branch Chief, at (202)551-3361 if you have questions
regarding comments on the financial statements and related matters. Please
contact Kyle Wiley,
Staff Attorney, at (202)344-5791 or Jan Woo, Legal Branch Chief, at
(202)551-3453 with any
other questions.
Sincerely,
FirstName LastNameEric Lefkofsky
Division of
Corporation Finance
Comapany NameTempus Labs, Inc.
Office of Technology
November 29, 2021 Page 2
cc: Courtney Tygesson
FirstName LastName