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United States securities and exchange commission logo
April 19, 2024
Gagan Dhingra
Interim Chief Financial Officer
Lucid Group, Inc.
7373 Gateway Boulevard
Newark, CA 94560
Re: Lucid Group, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2023
Filed February 27,
2024
File No. 001-39408
Dear Gagan Dhingra:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
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.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Cost of Revenue, page 77
1. Please tell us and
expand your disclosures to provide additional insight for the increase in
inventory and firm
purchase commitments write-downs in 2023. Additionally, expand
your critical
accounting policy disclosures to identify the material assumptions you used
in determining the
allowance for excess or obsolete inventory, including more details
of how you develop
certain assumptions such as current and future demand forecasts.
Note 2 - Summary of Significant Accounting Policies
Segment Reporting, page 98
2. Please disclose
revenues from external customers attributed to your country of domicile
and attributed to all
foreign countries in total from which you derive revenues in future
filings. In addition,
disclose long-lived assets located in your country of domicile and
located in all foreign
countries in total in which you hold assets. Also disclose the amount
Gagan Dhingra
Lucid Group, Inc.
April 19, 2024
Page 2
of revenues from external customers attributed to and the amount of
long-lived assets in
an individual foreign country, if material. Refer to ASC 280-10-50-41.
Revenue from Contracts with Customers, page 101
3. Please tell us whether the revenue recognition policies disclosed for
vehicle sales without
Residual Value Guarantee apply to vehicles sales under the EV Purchase
Agreement. If
different, please disclose in future filings the revenue recognition
policies applied to
vehicle sales under the EV Purchase Agreement.
Note 20 - Related Party Transactions, page 129
4. We note you disclosed various related party transactions. Please
identify on the face of
your consolidated balance sheets, consolidated statements of
operations and
comprehensive loss, and consolidated statements of cash flows the
amounts of all related
party transactions and balances in future filings pursuant to Rule
4-08(k) of Regulation S-
X.
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.
Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at
202-551-3777 with
any questions.
FirstName LastNameGagan Dhingra Sincerely,
Comapany NameLucid Group, Inc.
Division of
Corporation Finance
April 19, 2024 Page 2 Office of
Manufacturing
FirstName LastName