United States securities and exchange commission logo

                              November 1, 2023

       Paul Kim
       Chief Financial Officer
       Fulgent Genetics, Inc.
       4399 Santa Anita Avenue
       El Monte, California 91731

                                                        Re: Fulgent Genetics,
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            Filed February 28,
                                                            File No. 001-37894

       Dear Paul Kim:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment(s).

              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 Fiscal Year Ended December 31, 2022

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, page 54

   1.                                                   We note that the
significant decline in COVID-19 testing revenues has significantly
                                                        impacted your results
of operations for fiscal year 2022. As these revenues are not
                                                        anticipated to be a
material part of your ongoing results of operations, please provide an
                                                        analysis of the
material factors that impact the revenues that are expected to be a material
                                                        part of your results of
operations going forward in comparison to the corresponding
                                                        revenues for the prior
period. Also provide a discussion and analysis of the material
                                                        factors impacting the
associated gross profit for these revenues to provide investors with a
                                                        better understanding of
your future expectations of your operating results with the
                                                        remaining primary
diagnostic testing revenues. When multiple factors are discussed,
                                                        quantify the extent to
which each factor impacted the related operating result line items.
                                                        Refer to Item 303(b)(2)
of Regulation S-K and Section 501.12 of the Financial Reporting
                                                        Codification for
 Paul Kim
FirstName LastNamePaul   Kim
Fulgent Genetics, Inc.
Comapany 1,
November  NameFulgent
             2023       Genetics, Inc.
Page 2    1, 2023 Page 2
FirstName LastName
2.       We note that you incur research and development expenses related to
your diagnostics
         testing business and for your therapeutics development business.
Please expand your
         discussion and analysis to quantify the costs for each of your
research and development
         projects and to discuss the nature of the costs incurred for each
Critical Accounting Policies and Use of Estimates
Valuation of Goodwill and Intangible Assets, page 59

3.       We note that you recognized $143 million of goodwill and $64.6 million
of IPR&D, an
         indefinite-lived intangible asset, as of December 31, 2022. Please
provide a more
         comprehensive discussion and analysis of the critical estimates
associated with assessing
         goodwill and the indefinite-lived intangible asset for impairment. In
this regard, we note
         that the fourth quarter of fiscal year 2022 is the first time you
recognized operating and
         net losses since the second quarter of fiscal year 2020 due to the
significant decline in
         revenues from COVID-19 testing. Expanded disclosures are to provide
investors with
         sufficient information to assess any material uncertainty regarding
the realizability of
         goodwill and the indefinite-lived intangible asset, including but not
limited to the
             The percentage by which the estimated fair value exceeds the
carrying value of your
              reporting unit(s) or indefinite-lived intangible asset to the
extent that the fair value
              does not substantially exceed the carrying value.
             The methodologies used to estimate the fair value of the reporting
unit(s) and the
              indefinite-lived intangible asset for the most recent
quantitative assessment, including
              the material judgements, assumptions and estimates made.
             A discussion of the degree of uncertainty associated with the key
assumptions and
              estimates along with the potential impact reasonably possible
changes in the key
              assumptions would have on your impairment analysis.
             A discussion of the potential events and/or changes in
circumstances that could
              reasonably be expected to occur and negatively affect the key
assumptions and result
              in a material impairment charge.
         Refer to Item 303(b)(3) of Regulation S-K and Section 501.14 of the
Financial Reporting
         Codification for guidance.
Note 2. Summary of Significant Accounting Policies
Goodwill, page F-13

4.       Please expand your accounting policy to disclose the level at which
you are testing
         goodwill for impairment (i.e., the identification of your reporting
unit(s)). Also disclose
         when you perform your annual impairment test, the circumstances in
which you would
         perform an interim impairment test, and the method(s) used to estimate
the fair value of
         your reporting unit(s) to the extent that you prepare a quantitative
Reporting Segment and Geographic Information, page F-15

5.       We note your disclosure that you view your operations and manage your
business in one
 Paul Kim
Fulgent Genetics, Inc.
November 1, 2023
Page 3
            reporting segment   . We further note that you acquired Fulgent
Pharma, a clinical-stage,
         therapeutics development company, which differs from your historical
clinical diagnostic
         business. As such, please tell us your consideration of the guidance
in ASC 280-10-50-1
         through 50-5 for the identification of your operating segments and/or
reportable segments.
Note 15. Business Combinations
Fulgent Pharma Holdings, Inc, page F-33

6.       We note that you acquired Fulgent Pharma with one drug candidate for
which IPR&D of
         $64.6 million was recognized compared to the purchase price of $68
million. Please
         address each of the following:
             Provide us with your analysis of the guidance in ASC 805-10-55-5A
through 55-5C,
             including the calculation of the screen test.
             To the extent that you are able to demonstrate the screen test is
not met, provide us
             with your analysis of Fulgent Pharma meeting the definition of a
business based on
             the guidance in ASC 805-10-55.

       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 Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355 with
any questions.

FirstName LastNamePaul Kim
                                                              Division of
Corporation Finance
Comapany NameFulgent Genetics, Inc.
                                                              Office of
Industrial Applications and
November 1, 2023 Page 3                                       Services
FirstName LastName