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July 2, 2024
Cory Sindelar
Chief Financial Officer
Calix, Inc.
2777 Orchard Parkway
San Jose, California 95134
Re: Calix, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Form 8-K filed April 22, 2024
File No. 001-34674
Dear Cory Sindelar:
We have reviewed your June 17, 2024 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 June 4,
2024 letter.
Form 8-K filed April 22, 2024
Exhibit 99.2, page 15
1. We note your response to prior comment 1. As the write-off of inventory
and accrued
liabilities related to excess components at suppliers related to your
legacy product set
appears to be a normal, recurring operating expense, please remove the
non-GAAP
adjustment for Inventory and component liability charges. Refer to
Question 100.01 of the
Division of Corporation Finance s Compliance & Disclosure
Interpretations on Non-
GAAP Financial Measures.
Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at
202-551-3361 if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,
July 2, 2024
Page 2
Division of Corporation Finance
Office of Technology