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United States securities and exchange commission logo
December 15, 2021
William Koschak
Chief Financial Officer
Calyxt, Inc.
2800 Mount Ridge Road
Roseville, Minnesota 55113
Re: Calyxt, Inc.
Form 10-K for the
Year Ended December 31, 2020
Form 10-Q for the
Period Ended September 30, 2021
File No. 001-38161
Dear Mr. Koschak:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2020
Short-Term Investments, page F-7
1. Please explain why you
classified your short-term investments as trading and why the
corresponding cash
flows have been classified as investing instead of as operating in your
Statements of Cash
Flows. See ASC 320 and ASC 230-10-45-20.
Revenue Recognition - Product Sales, page F-9
2. In regards to your
revenue recognition policy related to product sales, please address the
following:
We note that you
may sell grain to a processor with a commitment to repurchase any
soybean meal
resulting from their grain crushing activity with a single net cash
settlement
occurring between the parties. In these instances, you recognize revenue
from the sale of
grain in the amount of the final net cash settlement with the
processor. Please
help us better understand and correspondingly expand your
William Koschak
Calyxt, Inc.
December 15, 2021
Page 2
disclosures to better explain what consideration you gave to the
guidance in ASC
606-10-25-26 as well as ASC 606-10-55-66 through 55-78 in
determining your
revenue recognition policy related to these sales which are subject
to a repurchase
agreement; and
In regards to the bill and hold arrangements in which you sell
grain to a processor and
your storage facility continues to be used to hold the grain until
such time it
is requested it be delivered, please help us better understand and
correspondingly
expand your disclosures to better explain what consideration you
gave to the
guidance in ASC 606-10-55-81 in determining your revenue recognition
policy
related to these arrangements. Please specifically address what
consideration you
gave as to whether there could be additional performance obligations
in these
arrangements such as custodial services.
Form 10-Q for the Period Ended September 30, 2021
Balance Sheet, page 4
3. Please quantify the components within your inventory balance as required
by Article 10-
01(a)(2) of Regulation S-X.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Nudrat Salik at (202) 551-3692 or Al Pavot at (202)
551-3738 with any
questions.
Sincerely,
FirstName LastNameWilliam Koschak
Division of
Corporation Finance
Comapany NameCalyxt, Inc.
Office of Life
Sciences
December 15, 2021 Page 2
cc: Debra Frimerman
FirstName LastName