United States securities and exchange commission logo
April 12, 2022
Omid Farokhzad, M.D.
Chief Executive Officer
Seer, Inc.
3800 Bridge Parkway, Suite 102
Redwood City, California 94065
Re: Seer, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-39747
Dear Mr. Farokhzad:
We have limited our review of your filing to the financial
statements and related
disclosures 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 Fiscal Year Ended December 31, 2021
Financial Statements
Note 5. Revenue and Deferred Revenue, page 104
1. Please tell us your
consideration of the guidance in ASC 606-10-50-5 related
to disaggregation of
revenue.
Note 10. PROGNOMIQ, INC., page 110
2. Please tell us your
consideration of providing summarized financial information for
your equity method
investment in PrognomIQ, Inc. pursuant to Rule 4-08(g) of
Regulation S-X.
Omid Farokhzad, M.D.
Seer, Inc.
April 12, 2022
Page 2
In closing, 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.
You may contact Christie Wong at (202) 551-3684 or Brian Cascio,
Accounting Branch
Chief, at (202) 551-3676 with any questions.
FirstName LastNameOmid Farokhzad, M.D. Sincerely,
Comapany NameSeer, Inc.
Division of
Corporation Finance
April 12, 2022 Page 2 Office of Life
Sciences
FirstName LastName