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Nevro

nvro · NYSE Healthcare
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FY2016 Annual Report · Nevro
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UNITED STATES 
SECURITIES AND EXCHANGE COMMISSION 
Washington, D.C. 20549 

FORM 10-K 

☒  Annual report pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 

For the year ended December 31, 2016 
or 

☐  Transition report pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 

Commission File Number: 001-36715 

NEVRO CORP. 

(Exact name of registrant as specified in its charter) 

Delaware 
(State or other jurisdiction of 
incorporation or organization) 

56-2568057 
(I.R.S. Employer 
Identification No.) 

1800 Bridge Parkway 
Redwood City, California 94065 
(Address of principal executive offices and zip code) 
(650) 251-0005 
(Registrant’s telephone number, including area code) 
Securities registered pursuant to Section 12(b) of the Act: 

Title of each class 
Common Stock, par value $0.001 per share

Name of exchange on which registered 
New York Stock Exchange 

Securities registered pursuant to Section 12(g) of the Act: None 

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities 

Act.    Yes  ☒    No  ☐ 

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Exchange Act 

of 1934 (the “Exchange Act”).    Yes  ☐    No  ☒ 

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Exchange 

Act during the preceding 12 months (or for such shorter period that the registrant was required to file such reports) and (2) has been 
subject to such filing requirements for the past 90 days.    Yes  ☒    No  ☐ 

Indicate by check mark whether the Registrant has submitted electronically and posted on its corporate website, if any, every 

Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T during the preceding 12 months (or for 
such shorter period that the Registrant was required to submit and post such files).    Yes  ☒    No  ☐ 

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K is not contained herein, and will 
not be contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III 
of this Form 10-K or any amendment to this Form 10-K.  ☒ 

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller 
reporting company. See the definitions of “large accelerated filer,” “accelerated filer,” and “smaller reporting company” in Rule 12b-2 of 
the Exchange Act. 
Large accelerated filer    ☒ 
  ☐ 
Non-accelerated filer 

Accelerated filer 
Smaller reporting company 

☐
☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange 

Act).    Yes  ☐    No  ☒ 

As of June 30, 2016, the last business day of the Registrant’s most recently completed second fiscal quarter, the aggregate market 

value of the common stock held by non-affiliates of the registrant was approximately $1,652 million based on the closing sale price for 
the registrant’s common stock on The New York Stock Exchange on that date of $73.76 per share. 

As of February 14, 2017, there were 29,183,202 shares of the registrant’s Common Stock outstanding. 

DOCUMENTS INCORPORATED BY REFERENCE 
Portions of the registrant’s Proxy Statement for the registrant’s 2017 Annual Meeting of Stockholders are incorporated by 
reference into Part III of this Form 10-K to the extent stated herein. The Proxy Statement will be filed within 120 days of the registrant’s 
fiscal year ended December 31, 2016.   

 
 
 
 
 
 
 
 
NEVRO CORP. 
TABLE OF CONTENTS 

Item 1.  Business 
Item 1A. Risk Factors 
Item 1B. Unresolved Staff Comments 
Item 2.  Properties 
Item 3.  Legal Proceedings 
Item 4.  Mine Safety Disclosures 

PART I

PART II

Item 5.  Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of 

Equity Securities 

Item 6.  Selected Financial Data 
Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of Operations 
Item 7A. Quantitative and Qualitative Disclosures About Market Risk 
Item 8.  Financial Statements and Supplementary Data 
Item 9.  Changes in and Disagreements with Accountants On Accounting and Financial Disclosure 
Item 9A. Controls and Procedures 
Item 9B. Other Information 

PART III

Item 10.  Directors, Executive Officers and Corporate Governance 
Item 11.  Executive Compensation 
Item 12.  Security Ownership of Certain Beneficial Owners and Management and Related Stockholder 

Matters 

Item 13.  Certain Relationships and Related Transactions, and Director Independence 
Item 14.  Principal Accountant Fees and Services 

Item 15.  Exhibits and Financial Statement Schedules 
Item 16.  Form 10-K Summary 
Signatures 

PART IV

Page No.

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ITEM 1. BUSINESS 

Overview 

PART I 

We are a global medical device company focused on providing innovative products that improve the quality of 

life of patients suffering from chronic pain.  We have developed and commercialized the Senza spinal cord 
stimulation (SCS) system, an evidence-based neuromodulation platform for the treatment of chronic pain. Our 
proprietary paresthesia-free HF10 therapy, delivered by our Senza system, was demonstrated in our SENZA-RCT 
study to be superior to traditional SCS therapy with it being nearly twice as successful in treating back pain and 1.5 
times as successful in treating leg pain when compared to traditional SCS therapy.  Comparatively, traditional SCS 
therapy has limited efficacy in treating back pain and is used primarily for treating leg pain, limiting its market 
adoption. Our SENZA-RCT study, along with our European studies, represents what we believe is the most robust 
body of clinical evidence for any SCS therapy. We believe the superiority of HF10 therapy over traditional SCS 
therapies will allow us to capitalize on and expand the approximately $1.6 to $1.8 billion existing global SCS 
market by treating back pain in addition to leg and pain without paresthesia. 

We launched Senza commercially in the United States in May 2015, after receiving a label from the U.S. Food 

and Drug Administration (FDA) which supports the superiority of our HF10 therapy over traditional SCS.  The 
Senza system has been commercially available in certain European markets since November 2010 and in Australia 
since August 2011. We have experienced consistent significant revenue growth in the United States since 
commercial launch and, effective January 1, 2016, received transitional pass-through payment under the Medicare 
hospital outpatient prospective payment system. In addition, on the basis of our strong clinical evidence, Senza is 
currently reimbursed by each of the top 10 national insurance providers. In early 2017, we commenced a controlled 
commercial launch of our surgical lead, marketed as the SurpassTM surgical lead, which we believe will provide us 
access to an additional approximately 30% of the U.S. SCS market. The tables below sets forth our revenue from 
U.S. and international sales the past two years on a quarterly basis and total revenue for each of the past three years.  

Q1 2015      Q2 2015  

  Q3 2015  

  Q4 2015  

  Q1 2016  

  Q2 2016       Q3 2016  

  Q4 2016  

(in millions) 

Revenue from U.S. sales 
Revenue from international sales   
$ 
Total sales revenue 

4.5    $ 19.8    $ 29.5    $ 40.6      $  47.2    $ 56.0 
N/A      $
9.7       
14.5 
9.7      $ 11.4    $ 15.4    $ 33.1    $ 41.7    $ 55.4      $  60.9    $ 70.5  

0.1    $
11.3     

14.8         13.7     

13.3     

12.2     

10.9     

Total revenue 

$

32.6     $

69.6      $ 

228.5  

2014 

2015 
(in millions) 

2016 

With a primary focus on treating leg pain, the global market for SCS therapy was estimated to be 

approximately $1.6 to $1.8 billion in 2016 and is expected to grow to approximately $2.5 billion per year by 2020. 
The United States represents approximately 80% of this global market due in part to governmental reimbursement 
restraints in international markets. We believe that due to factors such as an aging population and an increasing 
number of failed back surgeries, there is an opportunity for an SCS therapy that effectively treats back pain to create 
an incremental opportunity approximately the size of the existing SCS market over time. 

We believe our HF10 therapy will continue to both take share of and expand the SCS therapy market due to 

HF10 therapy being a paresthesia-free therapy and having superior efficacy when compared to traditional SCS 
therapies. Traditional SCS therapy generates paresthesia, a sensation typically experienced as tingling, numbness 
and buzzing, which overlaps the pain area. Paresthesia is often considered unpleasant or uncomfortable, sometimes 
causes a shocking or jolting sensation with changes in posture and is a continuous reminder of the patient’s chronic 
condition. Compared to traditional SCS therapy which typically operates at 50 Hz to 60 Hz, HF10 therapy delivers 
spinal cord stimulation at a lower amplitude and a higher frequency waveform of 10,000 Hz. In addition, HF10 
therapy relies on consistent anatomical placement of the stimulation leads across patients, thus reducing procedure 
variability relative to traditional SCS therapy which requires individualized lead placement to properly map 

1 

 
 
  
  
 
 
  
 
  
  
  
 
  
 
paresthesia coverage. We believe the ability of HF10 therapy to deliver pain relief without paresthesia provides a 
substantial benefit over traditional SCS therapy to patients and physicians. 

We believe the clinical results from our SENZA-RCT study, along with our European studies, position us with 

superior and compelling efficacy data. The following charts provide a comparison of HF10 therapy in both pain 
reduction and responder rates against the other prospective Level 1 studies conducted.  

1. 

2. 

3. 

4. 

Al-Kaisy A, et. al. Sustained effectiveness of 10 kHz high-frequency spinal cord stimulation for patients with chronic, low back pain: 24-month results of a prospective multicenter 
study. Pain Med. 2014;15:347-354.  Internal data on file. 
Kapural, Leonardo et. al. Novel 10-kHz High-frequency Therapy (HF10 Therapy) Is Superior to Traditional Low-frequency Spinal Cord Stimulation for the Treatment of Chronic 
Back and Leg Pain: The SENZA-RCT Randomized Controlled Trial. Anesthesiology Vol. 123 No 4. October 2015. 
Kumar K et al., Spinal cord stimulation versus conventional medical management for neuropathic pain: A multicentre randomised controlled trial in patients with failed back 
surgery syndrome, Pain (2007), doi:10.1016/j.pain.2007.07.028.  6-month data shown. 
St. Jude Medical Proclaim™ Implantable Pulse Generator Clinician's Manual, Models 3660, 3662, 3665, 3667. Published on www.sjm.com October 2016. 

1. 

2. 

3. 

4. 

Al-Kaisy A, et. al. Sustained effectiveness of 10 kHz high-frequency spinal cord stimulation for patients with chronic, low back pain: 24-month results of a prospective multicenter 
study. Pain Med. 2014;15:347-354.  Internal data on file. 
Kapural, Leonardo et. al. Novel 10-kHz High-frequency Therapy (HF10 Therapy) Is Superior to Traditional Low-frequency Spinal Cord Stimulation for the Treatment of Chronic 
Back and Leg Pain: The SENZA-RCT Randomized Controlled Trial. Anesthesiology Vol. 123 No 4. October 2015. 
Kumar K et al., Spinal cord stimulation versus conventional medical management for neuropathic pain: A multicentre randomised controlled trial in patients with failed back 
surgery syndrome, Pain (2007), doi:10.1016/j.pain.2007.07.028.  6-month data shown. 
St. Jude Medical Proclaim™ Implantable Pulse Generator Clinician's Manual, Models 3660, 3662, 3665, 3667. Published on www.sjm.com October 2016. 

2 

 
 
 
In November 2016, we filed a lawsuit for patent infringement against Boston Scientific Corporation and 
Boston Scientific Neuromodulation Corporation (collectively, “Boston Scientific”) asserting that Boston Scientific 
is infringing our patents covering inventions related to our HF10 therapy and the Senza system.  Following our 
lawsuit, in December 2016, Boston Scientific countered with a patent infringement lawsuit against us, alleging that 
we infringed Boston Scientific’s patents covering SCS technology related to stimulation leads, rechargeable 
batteries and telemetry.  Each of the lawsuits seek preliminary and permanent injunctive relief against further 
infringement as well as damages and attorney fees.  

We believe we have built competitive advantages through our proprietary technology, clinical evidence base, 
strong track record of execution with over 15,000 patients implanted with Senza, extensive intellectual property and 
a proven management team with substantial neuromodulation experience. With the well-demonstrated superior 
efficacy of our HF10 therapy, we aim to continue to drive adoption and penetration in the U.S. market, which 
represents the largest opportunity in SCS, and expand patient access to HF10 therapy by investing in the 
development of evidence for new indications such as chronic upper limb and neck pain, painful neuropathies and 
non-surgical refractory back pain. 

Market Overview 

Existing Treatments for Chronic Pain and Limitations 

Chronic pain has been defined as pain that lasts longer than the time required for tissues to heal, which is often 

considered to be three months.  Patients who present with chronic pain are typically placed on a treatment 
progression plan. Initial medical management typically includes behavioral modification, exercise, physical therapy 
and over-the-counter analgesics and non-steroidal anti-inflammatory drugs. When early stage medical management 
is not sufficient for the treatment of chronic leg and back pain, patients may progress to interventional techniques 
including steroid injections or nerve blocks. Patients who do not respond to these more conservative treatments are 
considered candidates for more advanced therapies.  These more advanced therapies include spine surgery, 
treatment with oral opioids and SCS.  Spine surgery, while a common invasive procedure, can result in 
complications such as Failed Back Surgery Syndrome, or FBSS, a condition where pain persists despite the 
procedure, and spinal surgery often fails to treat certain types of chronic pain such as severe neuropathic back pain.  
Oral opioids, while reducing the patient’s perception of pain, lack clinical evidence to support long-term usage and 
can cause multiple complications and side-effects including nausea, vomiting and dizziness.  Further, opioids 
present a high risk of addiction and abuse.     

Traditional Spinal Cord Stimulation and Limitations 

SCS is a type of neuromodulation technology that utilizes an implantable, pacemaker-like device to deliver 

electrical impulses to the spinal cord to treat chronic pain.  Traditional SCS therapy is designed to induce 
paresthesia, a sensation typically experienced as tingling, numbness and buzzing, which overlaps the area of pain 
with the intent of masking pain perception. The electrical pulses are delivered by small electrodes on leads that are 
placed near the spinal cord and are connected to a battery-powered generator implanted under the skin. Traditional 
SCS therapy is currently indicated as a treatment for chronic pain of the trunk and limbs in patients who failed 
conventional medical management. Traditional SCS therapy is considered to be a minimally invasive and reversible 
therapy that may provide greater long-term benefits over more invasive surgical approaches or opioids. The most 
common use for traditional SCS therapy is for neuropathic pain conditions such as FBSS. 

Traditional SCS therapy generally consists of two phases, an evaluation period, also called the trial period, 

which typically lasts several days, followed by a permanent implant for those patients who experience a successful 
trial period. The trial period involves a percutaneously placed insulated wire, called a lead, which a physician 
implants near the spinal cord using a needle. During the trial period, a temporary external system is used by patients 
and physicians for evaluating whether traditional SCS therapy is effective. If the trial period is successful, a 
permanent system is implanted in the patient. The success criterion is typically an approximate 50% reduction in 
pain during the evaluation period. For those patients that proceed to the permanent implant procedure, we believe 
that approximately 30% of U.S. procedures are completed using surgical leads and the remaining are completed 
using percutaneous leads. 

3 

 
A key part of the permanent system is the implantable pulse generator, or IPG, which is a miniaturized version 

of the external stimulator. The IPG should provide the patient with multiple years of use and can be either 
rechargeable or non-rechargeable. Primary cell IPGs, or non-rechargeable IPGs, are used in cases where the patient 
requires a lower level of stimulation and such systems have a limited life. Rechargeable IPGs, a more recent 
innovation, can be  more expensive but allow for higher levels of stimulation and may last 10 years or more. Due to 
payor constraints in certain European countries, the transition from primary cell IPGs to rechargeable IPGs has been 
slow in those markets. In the United States and Australia, most IPGs implanted are rechargeable. 

Traditional SCS products have required paresthesia to provide pain relief, and consequently, paresthesia 
coverage has been used as a surrogate metric for successful pain relief. Paresthesia is often considered unpleasant or 
uncomfortable and is sometimes made worse by a shocking or jolting sensation with changes in posture. Unpleasant 
sensations can be caused by lead movement closer to the spinal cord or away from it as the patient moves, resulting 
in variation in paresthesia intensity. Paresthesia is also a constant reminder of the patient’s chronic condition. Due to 
the distraction of paresthesia, patients with traditional SCS devices are instructed not to drive or operate machinery 
when the device is active. Medtronic plc, or Medtronic, the current leader in neuromodulation, has released a survey 
showing that 71% of patients find paresthesia uncomfortable at times. As such, innovation in the SCS market has 
historically focused on technologies that optimize traditional SCS therapy’s ability to create more precise 
paresthesia fields. Even with successful paresthesia coverage, patients still may not receive pain relief or often lose 
pain relief after a period of time.  

Traditional SCS procedures also require physicians to perform the complex and often time-consuming process 
of paresthesia mapping. This mapping process requires a patient to be sedated for the lead placement, then awakened 
and repeatedly questioned in order for the physician to assess paresthesia coverage over the patient’s area of pain 
and reposition and reprogram the leads to redirect the paresthesia. This process creates variability in the procedure 
and a complicated anesthesia management process, impacting the physician’s schedule and patient comfort. The 
primary objective of traditional SCS therapy is to create a stimulation program that covers the areas of pain without 
creating paresthesia beyond the pain areas, given that this can be uncomfortable and difficult to tolerate. 

Our Solution for Chronic Pain 

HF10 Therapy 

Our HF10 therapy is designed to deliver innovative neuromodulation solutions for treating chronic pain based 

on what we believe to be the best clinical evidence available. By overcoming many of the limitations of traditional 
SCS therapy, our HF10 therapy offers superior efficacy for patients and provides significant advantages to 
physicians and hospitals. We believe the advantages of our proprietary HF10 therapy over traditional SCS include: 

 

 

 

Demonstrated superior efficacy data for both leg and back pain: In our SENZA-RCT pivotal study, 
HF10 therapy was demonstrated to provide significant and sustained back pain relief in addition to leg 
pain relief. HF10 therapy was shown in both number of patients that respond and in treatment efficacy 
to be superior to traditional SCS therapy as it is nearly twice as successful in treating back pain and 1.5 
times as successful in treating leg pain. Our SENZA-RCT study, along with the previously completed 
European studies, represent what we believe is the most robust body of clinical evidence for any SCS 
therapy. We believe that the superior efficacy results and robust data provided in our pivotal clinical 
trials will drive increased adoption of our HF10 therapy among patients, payors and providers and may 
enable us to gain significant market share in the approximately $1.6 to $1.8 billion existing global SCS 
market, which is primarily based on treating leg pain. In addition, we believe our efficacy data in back 
pain will allow us to expand the SCS market under current reimbursement regimes by meeting demand 
from back pain patients who are largely untreated by traditional SCS therapies. 

Paresthesia free pain relief for patients:  HF10 therapy offers the notable benefit to patients of 
achieving significant and sustained pain relief without paresthesia, thus enabling our patients to avoid 
the uncomfortable shocking or jolting sensations commonly associated with paresthesia, and removing a 
major barrier for many patients who may otherwise benefit from SCS therapy. 

Anatomical lead placement for physicians. Since HF10 therapy relies on consistent anatomical lead 
placement, it removes the cumbersome process of paresthesia mapping that is required by traditional 

4 

 
SCS therapy, reducing variability in the operating procedure and offering a significant benefit to both 
physicians and hospitals by reducing variability of procedures. 

 

Ability to treat a broader group of chronic pain patients: Our HF10 therapy is a platform technology 
that we believe can provide treatment benefits for a broader group of chronic pain indications. We are 
currently investigating the use of HF10 therapy to address additional indications such as chronic upper 
limb and neck pain, painful neuropathies and non-surgical refractory back pain. Based on analysis from 
our SENZA-RCT and European studies, we believe HF10 therapy may be an attractive treatment option 
for some non-surgical refractory back pain patients due to its cost, reversibility and initial trial period. 
Due to the removal of paresthesia, HF10 may also be an effective therapy for patients with chronic 
upper limb and neck pain as it will not create the intense discomfort that traditional SCS generates for 
patients with chronic upper limb and neck pain when leads are placed in the cervical spine.  

Our Growth Strategy 

Our mission is to be the neuromodulation leader in the treatment of chronic pain by developing innovative, 

evidence-based solutions. To accomplish this objective we intend to: 

 

 

 

 

Drive adoption of HF10 therapy through a world-class sales and marketing organization: We will 
continue to build our worldwide sales organization consisting of direct sales representatives and, in 
some international markets, a network of distributors and sales agents. In particular, we are continuing 
to make significant investments in building our U.S. commercial infrastructure and sales force. This is a 
lengthy process that requires significant investment to recruit and train qualified sales representatives. 
Following initial training for Senza, our sales representatives typically require lead time in the field to 
grow their network of accounts and produce sales results. Successfully recruiting and training a 
sufficient number of productive sales representatives is required to achieve our expected growth rate. As 
of December 31, 2016, we have 194 hired and trained sales representatives in the field in the United 
States.  Our sales representatives target physician specialties involved in SCS treatment decisions, 
including neurosurgeons, physiatrists, interventional pain specialists and orthopedic spine surgeons. 
Further, we expect that our direct sales force will target the approximately 2,400 hospitals and 
outpatient surgery centers, at which we believe an estimated 90% of SCS procedures in the United 
States are performed. To complement our sales representatives, we intend for our marketing and 
reimbursement teams to drive HF10 therapy adoption through creating awareness and demand among 
additional stakeholders involved in the SCS treatment decision, including third-party payors, hospital 
administrators, and patients and their families. Internationally, we plan to increase coverage in certain of 
our existing markets by continuing the expansion of our direct sales force. 

Expand the existing SCS market by treating back pain: We believe we are expanding the existing 
SCS market by delivering a system that provides meaningful treatment for chronic back pain, which we 
believe represents a significant opportunity in the global SCS market. With traditional SCS therapy, 
patients who experience predominant back pain are associated with lower levels of treatment success. 
Consequently, patients with back pain are typically not recommended for treatment with traditional SCS 
therapy due to the difficulty of achieving and maintaining pain coverage. In contrast to traditional SCS 
therapy, we believe HF10 therapy is positioned to expand the existing SCS market by effectively 
treating back pain in addition to leg pain.  

Communicate the clinically demonstrated, superior efficacy of HF10 therapy to patients, 
physicians and payors globally: Given our robust clinical evidence that demonstrates the superior 
efficacy of our HF10 therapy, we believe we will be able to position our therapy with patients, providers 
and payors in a differentiated way. Given that our SENZA-RCT pivotal study has demonstrated 
superiority for both back and leg pain in a head-to-head comparison with traditional SCS, we are able to 
differentiate HF10 therapy by communicating its superior clinical benefits and advantages to patients, 
physicians and payors. 

Invest in research and development to drive innovation: We are extending our novel and proprietary 
technologies into a series of product enhancements with the goal of improving the treatment of chronic 
pain. Product enhancements in development include a next-generation IPG and enhanced MRI 
capability.  Further, we have recently commenced a controlled commercial launch of our new surgical 

5 

 
leads, marketed as the Surpass surgical lead, which we believe will give access to approximately 30% of 
the U.S. SCS market that we previously did not address without the surgical lead. We believe product 
enhancements if and when completed will drive continued adoption of our technology platform and 
further validate the advantages and benefits of our HF10 therapy. 

 

Scale our business to achieve cost and production efficiencies: We plan to improve the efficiency of 
our third-party manufacturing processes, which we believe will lower our per unit manufacturing cost. 
We expect to continue to scale our manufacturing operations as we expand Senza sales volumes in the 
United States. 

Growth Opportunities in Other Chronic Pain Indications 

We plan to use our platform technology to develop HF10 therapy for use in other chronic pain indications 

with significant unmet medical need, including chronic upper limb and neck pain, non-surgical back pain and 
painful neuropathies. There can be no assurance that we will be successful in developing HF10 therapy for use in 
other indications or in receiving required regulatory approvals and reimbursement coverage to market Senza and 
HF10 therapy for use in other indications. Below are three areas where preliminary results have been promising: 

Chronic Upper Limb and Neck Pain 

Chronic neck pain with or without upper limb pain is prevalent in 48% of women and 38% of men in the general 

adult population, with persistent complaints in 22% of women and 16% of men. Multiple treatments currently exist in 
the market today, such as epidural injections, but there is a lack of clinically efficacious treatments for some patients. In 
addition, there has been a very small body of evidence published on the application of SCS in chronic neck pain and 
upper limb pain by placing the leads in the cervical spine. The evidence has suggested limited therapeutic response 
when traditional SCS therapy is used, where the paresthesia in the cervical spine associated with traditional SCS 
therapy can create intolerable discomfort, limiting its viability. We believe Senza can overcome this barrier due to its 
ability to deliver pain relief without paresthesia, combined with its demonstrated superior efficacy relative to the 
traditional SCS for back and leg pain. Early results from our SENZA Upper Limb and Neck study, which were 
presented at the North America Neuromodulation Society (NANS) conference in January 2017, demonstrated a 75% 
overall responder rate for 20 patients at three months. Further, average neck pain scores (as measured on the Visual 
Analog Scale (VAS)) declined from 7.5 (n=38) at baseline to 2.5 (n=20) at three months. For upper limb pain, average 
VAS scores declined from 7.0 (n=19) at baseline to 1.9 (n=12) at three months. 

Non-Surgical Back Pain (Pre-Spinal Surgery) 

One of the most common uses for SCS is for neuropathic pain conditions such as FBSS. The incidence of 
patients that will develop FBSS following lumbar spinal surgery is estimated to be within the range of 10% to 40%. 
With the increasing number of spinal surgeries in the United States, FBSS is also increasing. While there is a clear 
need for spinal surgery in many patients, given the high rate of FBSS there is a potential for SCS to move up the 
treatment progression ahead of spinal surgery for some patients without mechanical instability. HF10 therapy could 
provide an attractive treatment option for these patients due to its cost, reversibility and initial trial period. In subset 
analysis of pre-spinal surgery patients from our SENZA-RCT and European studies, respectively, we found a 
decrease in back pain VAS scores from 7.2 to 2.5 (12 months, n=11) and 8.1 to 3.4 (24 months, n=14), respectively, 
as well as a decrease in leg pain VAS scores from 7.1 to 2.3 (12 months, n=11) and 5.9 to 2.8 (24 months, n=14), 
respectively. More recent results in patients treated with HF10 therapy with no history of spinal surgery from a study 
led by Adnan Al-Kaisy demonstrated similar promising results. In this study, patients experienced reduced back pain 
VAS and Oswestry Disability Index (ODI) scores from baseline of 73% and 48% respectively at 12 months (n=20). 
In addition to pain reduction and reduced disability, a reduction in opioid use of 64% was also observed in this 
study. 

Painful Neuropathies 

The American Chronic Pain Association estimates that more than 15 million people in the United States and 

Europe have some degree of neuropathic pain. More than two out of every 100 people are estimated to have 
peripheral neuropathy, with the incidence rate increasing to eight in every 100 for people aged 55 or older. The 

6 

 
diminished quality of life and increased disability associated with peripheral neuropathy results in significant 
workforce and healthcare costs. Various treatments currently exist, but have limited efficacy. As such, we have 
initiated an initial study to determine if HF10 therapy could help this patient group. Preliminary results of a 
prospective, multicenter feasibility study treating chronic intractable pain of the limbs from peripheral 
polyneuropathy using HF10 therapy demonstrated a decrease in mean VAS pain score from 7.6 cm at baseline 
(N=26) to 2.1 cm at one month post-implant (N=16), with 81% of subjects deemed responders (abstract presented at 
NANS in January 2017). 

Clinical Data 

To support development of our proprietary HF10 therapy, the technology was evaluated in preclinical studies 

and further studied in prospective clinical trials, all of which have now been published. Key highlights of our 
SENZA-RCT pivotal study are as follows: 

 

 

 

 

 

 

 

Our SENZA-RCT study results demonstrated the superiority of HF10 therapy to traditional SCS therapy 
on all primary and secondary endpoints through 24 months. 

HF10 therapy was nearly twice as successful in treating back pain as traditional SCS therapy, with 
84.3% of patients receiving HF10 therapy reporting 50% or more pain relief at three months, as 
compared to 43.8% of patients receiving traditional SCS therapy. The superiority of HF10 therapy for 
treating back pain was maintained through the 24-month follow-up period of the study. 

HF10 therapy was 1.5 times as successful in treating leg pain as traditional SCS therapy, with 83.1% of 
patients receiving HF10 therapy, as compared to 55.5% of patients receiving traditional SCS therapy, 
reporting 50% or more pain relief at three months, results that were superior. The superiority of HF10 
therapy for treating leg pain was maintained through the 24-month follow-up period of the study. 

HF10 therapy provided a 69.2% reduction in back pain as measured by the Visual Analog Scale, or 
VAS, versus 44.2% for traditional SCS therapy, at three months, results that were superior. The 
superiority of HF10 therapy for reducing back pain was maintained through the 24-month follow-up 
period of the study.  HF10 therapy provided a 72.8% reduction in leg pain as measured by VAS, versus 
51.5% for traditional SCS therapy, at three months, results that were superior. The superiority of HF10 
therapy for reducing leg pain was maintained through the 24-month follow-up period of the study.  
Superiority of HF10 therapy to traditional SCS therapy demonstrated for both back and leg pain at each 
designated study endpoint throughout 24 months. 

Patients receiving HF10 therapy did not report paresthesia or uncomfortable stimulation at three months. 
In comparison, 46.5% of patients receiving traditional SCS therapy reported uncomfortable stimulation 
at three months. 

Two-thirds of HF10 therapy patients had a VAS pain score of less than or equal to 2.5 on a scale of 0 to 
10 for back pain at three months (which we define as achieving remitter status), twice the number of 
traditional SCS therapy patients, results that were statistically superior. The superiority of HF10 therapy 
for achieving remitter status for back pain was maintained through the 24-month follow-up period of the 
study. 

Three-fourths of HF10 therapy patients had a VAS pain score of less than or equal to 2.5 on a scale of 0 
to 10 for leg pain at three months, twice the number of traditional SCS therapy patients, results that were 
statistically superior. The superiority of HF10 therapy for achieving remitter status for leg pain was 
maintained through the 24-month follow-up period of the study. 

 

Safety outcomes were consistent across the control and test groups. 

The results from the clinical studies have been consistent across studies and across outcome measures. Our 
prospective multicenter European clinical study (EU) further supported the findings of our prospective, comparative, 
randomized, controlled U.S. pivotal study (SENZA-RCT). In the two-year follow up of the EU study, average back 
pain VAS was reduced from 8.4 at baseline to 2.8 at 12 months to 3.3 at 24 months. Average leg pain was reduced 
from 5.4 VAS pain level at baseline to 2.0 at 12 months to 2.3 at 24 months. Additionally, for responder rates, 60% 
of the implanted patients had at least 50% back pain relief and 71% had at least 50% leg pain relief. Disability as 

7 

 
measured by ODI improved by an average of 15 points at 24 months, a clinically and statistically significant 
improvement. The following table summarizes key outcomes for implanted subjects in our EU and SENZA-RCT 
studies. 

Back pain responders 
HF10 therapy (%) 
Traditional SCS (%) 
Superiority p-value 
Leg pain responders 
HF10 therapy (%) 
Traditional SCS (%) 
Superiority p-value 

Back pain reduction from Baseline 

HF10 therapy (%) 
Traditional SCS (%) 
Superiority p-value 

Leg pain reduction from Baseline 

HF10 therapy (%) 
Traditional SCS (%) 
Superiority p-value 

Month 3 

Month 6 

Month 12 

Month 24 

EU 

RCT 

EU 

RCT 

EU 

RCT 

EU 

RCT 

82.9 

82.9 

71.3 

75.3 

84.3 
43.8 
<0.001 

83.1 
55.0 
<0.001 

69.2 
44.2 
<0.001 

72.8 
51.5 
<0.001 

73.6 

86.0 

67.7 

73.4 

76.4 
52.5 
0.001 

80.9 
55.0 
<0.001 

62.4 
44.3 
<0.001 

66.9 
49.9 
0.002 

70.1 

65.0 

64.9 

61.6 

78.7 
51.3 
<0.001 

80.9 
50 
<0.001 

66.4 
44.7 
<0.001 

69.5 
48.0 
<0.001 

60.0 

76.5 

71.1 

72.9 

59.6 

66.9 

61.6 

65.1 

Our SENZA-RCT pivotal study was a prospective, randomized, multi-center study, conducted across 11 U.S. 

clinical trial sites, comparing the safety and effectiveness of Senza delivering HF10 therapy, which we refer to as the 
test to Boston Scientific’s FDA-approved Precision Plus system, delivering traditional SCS therapy, which we refer 
to as the control. Each included patient was required to have a leg and back pain VAS score of at least 5. Among the 
198 chronic pain patients who were randomized for treatments, 171 had a successful therapy evaluation phase, or 
trial phase, and were implanted with an SCS system. The study was designed as a non-inferiority trial and met its 
primary and secondary endpoints. Statistical analysis also demonstrates the superior efficacy of HF10 therapy over 
traditional SCS therapy for all primary and secondary endpoints.  

The 12-month outcomes for HF10 therapy in our SENZA-RCT pivotal study were published in 

Anesthesiology and are consistent with the outcomes from our European clinical study, the two year results of which 
have been published in the Pain Medicine journal of the American Academy of Pain Medicine. The 24-month 
SENZA-RCT results were presented in December 2015 at the annual meeting of the North American 
Neuromodulation Society, showing sustained superiority of HF10 therapy compared with traditional SCS in treating 
both back and leg pain over the 24-month follow-up period. The 24-month outcomes in our SENZA-RCT pivotal 
study were published in Neurosurgery. 

Patients with chronic pain are generally classified by physicians based on the location of their pain, for 
example whether their worst pain is predominant back, predominant leg, mixed back and leg, upper limb, neck or 
other. The adoption of SCS to date has been driven primarily by the treatment of patients whose worst pain is in 
their legs and for whom other treatment approaches have failed. We believe that broader utilization of traditional 
SCS therapy has been restrained by the lack of prospective randomized clinical evidence supporting SCS broadly 
and, in particular, demonstrating an ability to treat back pain. 

Safety Data (EU and RCT Studies) 

Safety results of our SENZA-RCT pivotal study were consistent between the test and control groups. Study-
related serious adverse events, or SAEs, occurred in 4.0% of HF10 therapy subjects (n=4) compared with 7.2% of 
traditional SCS therapy subjects (n=7; p = 0.37). In addition to the SAEs described above, there were two deaths, 
one of which was study-related and resulted from a myocardial infarction of a subject randomized to traditional SCS 
therapy that occurred during the implant procedure. The other death occurred outside the study period in the test 
group and resulted from a malignant hepatic neoplasm. The most common study-related AEs were implant site pain 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(in 11.9% of HF10 therapy and 10.3% of traditional SCS therapy subjects) and uncomfortable paresthesia (in 11.3% 
of traditional SCS therapy participants). Lead migration leading to revision occurred in 3.0% of HF10 therapy and 
5.2% of traditional SCS therapy participants. Importantly, neurological assessment revealed no stimulation-related 
neurological deficits in either treatment group. Also, there were no stimulation-related SAEs in either arm. 

Safety results of our EU study demonstrated no evidence of neurologic deficit or dysfunction attributable to 
prolonged delivery of HF10 therapy. Further, investigators reported that adverse events were similar in nature and 
frequency to those seen with traditional SCS therapy. The most common adverse events in both arms of the study 
were implant site pain, infection and lead migration. 

Our Senza System 

The Senza system is approved to create electrical impulses from 2 Hz to 10,000 Hz, including our proprietary 

HF10 therapy, which allows for pain relief without paresthesia. HF10 therapy delivers proprietary waveforms at 
10,000 Hz pulse rate with a statistically driven and clinically verified programming algorithm. 

Senza, similar to other commercially available SCS systems, consists of leads, a trial stimulator, an IPG, 
surgical tools, a clinician laptop programmer, a patient remote control and a mobile charger. These components 
enable physicians to implant the leads and the IPG, and patients to operate the system. 

Implantable Pulse Generator (IPG): The IPG contains a rechargeable battery and electronics that deliver 
electrical pulses to the lead. It can connect to one or two leads, and up to 16 electrodes. It is a programmable device 
and can deliver the required customized programs for each patient. The IPG is rechargeable and is placed surgically 
under the skin, usually above the buttock or the abdomen. The Senza SCS system is CE Marked and FDA-approved 
with labeling for “at least 10 year battery life”. 

Percutaneous Leads: The percutaneous leads vary in length and are thin, insulated medical wires in a 

cylindrical, flexible and steerable shape that conduct electrical pulses from the IPG to near the spinal cord. The 

9 

 
 
 
 
 
insertion of the percutaneous leads can also be minimally invasive as they can be inserted in the epidural space 
through a needle. 

Surpass Surgical Leads: The Surpass surgical leads are similar to our percutaneous leads but in a larger 
paddle-shaped format that provides a larger surface area that broadens exposure of the lead along the vertebrae. Our 
Surpass surgical leads received initial approval from the FDA in late 2016 with a further approval received in 
January 2017 and we commenced a controlled commercial launch in early 2017.   We believe the availability of 
Surpass leads will give access to up to approximately 30% of the U.S. SCS market that we previously did not 
address without a surgical lead. 

Trial Stimulator: The trial stimulator contains electronics that deliver electrical pulses to the lead. It is an 
external device that is worn around the waist during the evaluation period that typically lasts several days. It is 
powered by batteries. 

Surgical Tools: Surgical tools include percutaneous insertion needles that are used to introduce the lead into 

the epidural space, a variety of stylets that give physicians the ability to steer and deliver the lead to the desired 
location, anchors to secure the leads and tunneling tools that provide access from the lead insertion site to the 
location of the IPG. 

Programmer:  The clinician laptop programmer contains proprietary software that allows the customized per 
patient programming of the IPG. It can non-invasively interrogate the IPG and transmit programming information 
and download diagnostic information. 

Patient Remote Control: The patient remote control is a handheld device that allows patients to turn their 

stimulation on and off and change programs uploaded to their IPG. 

Charger: The charger recharges the IPG from outside the body. To charge, the charging coil of the charger is 
placed over the location of the IPG and then initiated by pushing a button on the charger. The charger is mobile and 
can be worn around the waist using a belt when charging is needed, so that the patient can perform various tasks 

10 

 
 
 
 
 
while charging. Charging sessions are usually performed daily and are expected to average approximately 45 
minutes a day. 

Third-Party Coverage and Reimbursement 

In the United States, the primary purchasers of Senza are hospitals and outpatient surgery centers. These 

purchasers bill various third-party payors, such as Medicare, Medicaid and private health insurance plans for the 
healthcare services associated with the SCS procedure. Government agencies and private payors determine whether 
to provide coverage for specific procedures. In the United States, the Centers for Medicare & Medicaid Services, or 
CMS, administers the Medicare and Medicaid programs (the latter, along with applicable state governments). As the 
single largest payor, this program has a significant impact on other payors’ payment systems. 

Generally, reimbursement for services performed at a hospital or outpatient surgery center are reported using 

billing codes issued by the American Medical Association (AMA) known as Current Procedural Terminology, or 
CPT, codes. Physician reimbursement under Medicare generally is based on a fee schedule and determined by the 
relative values of the professional service rendered.  Hospital outpatient services, reported by CPT codes, are 
assigned to clinically relevant Ambulatory Payment Classifications (APCs) used to determine the Medicare payment 
amount for services provided. In addition, CMS and the National Center for Health Statistics (NCHS) are jointly 
responsible for overseeing changes and modifications to billing codes used by hospitals to report inpatient 
procedures, known as ICD-10-PCS codes on and after October 1, 2015. In the United States, CMS has approved a 
transitional pass-through payment for High-Frequency Stimulation under the Medicare hospital outpatient 
prospective payment system effective beginning January 1, 2016 and expiring December 31, 2017 unless renewed 
for an additional year, assigning a new Healthcare Common Procedure Coding System (HCPCS) Level II billing 
code to describe High-Frequency Stimulation.  This pass-through payment for HF10 therapy is in addition to the 
established reimbursement for spinal cord stimulation implant procedures and devices.  CMS determined that the 
Senza SCS System delivering HF10 therapy met the criteria for a new transitional pass-through device category 
based on evidence submitted from our SENZA-RCT study. We believe that SCS procedures using Senza are 
adequately described by existing CPT, HCPCS II, and ICD-10-PCS codes for the implantation of spinal cord 
stimulators and related leads performed in various sites of care. 

Medicare reimbursement rates for the same or similar procedures vary due to geographic location, nature of 
the facility in which the procedure is performed (i.e., hospital outpatient department or outpatient surgery centers) 
and other factors. Although private payors’ coverage policies and reimbursement rates can differ significantly from 
payor to payor, the Medicare program is frequently used as a model for how private payors and other governmental 
payors develop their coverage and reimbursement policies for healthcare items and services, including SCS 
procedures. For example, certain regional Blue Cross Blue Shield plans have denied coverage for Senza on the basis 
that high-frequency neuromodulation is investigational and/or experimental. We continue to engage in efforts to 
convince such payors of the advantages of HF10 therapy, however, there can be no assurances that we are successful 
in overturning negative coverage decisions by private health insurance plans. In addition, payors continually review 
new technologies for possible coverage and can, without notice, deny coverage for these new products and 
procedures. As a result, the coverage determination process is often a time-consuming and costly process that will 
require us to provide scientific and clinical support for the use of our products to each payor separately, with no 
assurance that coverage and adequate reimbursement will be obtained, or maintained if obtained. 

Outside the United States, reimbursement levels vary significantly by country, and by region within some 
countries. Reimbursement is obtained from a variety of sources, including government-sponsored and private health 
insurance plans, and combinations of both. Some countries will require us to gather additional clinical data before 
granting broader coverage and reimbursement for our products. It is our intent to complete the requisite clinical 
studies and obtain coverage and reimbursement approval beyond what we have today in countries where it makes 
economic sense to do so. 

Product Development and Research Development 

Our objective is to continue to improve patient outcomes and further expand patient access to HF10 therapy 

through enhancements to Senza and the development of new indications. Research and development, or R&D, 

11 

 
expenses were $19.8 million, $21.4 million and $33.7 million, for the years ended December 31, 2014, 2015 and 
2016, respectively. 

Since the launch of the initial Senza system, we have introduced a number of product enhancements. These 
include a short-tip version of the lead, new lengths of the lead, an active anchor with improved performance over 
silicon anchors, a second generation active anchor with smaller volume, lead adaptors that allow use of competitor 
leads already implanted in patients, second generation clinician programmer software, a second generation IPG with 
improved shape and compatibility for scans of the head and extremities with both 1.5 and 3 Tesla (T) MRI machines 
and our Surpass surgical lead to complement our percutaneous lead. We also expect to continue developing 
enhancements to Senza to further increase performance and introduce new benefits including next generation IPGs 
and enhanced MRI capabilities. There can be no assurance that we will be successful in these efforts or in receiving 
any required regulatory approvals. 

Sales and Marketing 

United States 

As of December 31, 2016, we had 194 hired and trained sales representatives in the field in the United States.  
Our sales representatives target physician specialties involved in SCS treatment decisions, including neurosurgeons, 
physiatrists, interventional pain specialists and orthopedic spine surgeons. We intend for sales representatives to 
reach target sales in the United States of $1.3 million to $1.5 million over a period of 12 to 15 months from initial 
field deployment. In addition, our commercial team plans to continue to create demand for Senza among additional 
stakeholders involved in the SCS treatment decision, including third-party payors, hospitals administrators and SCS 
patients and their families. We have also developed a clinical support team in order to provide ongoing support to 
physicians and patients for the use of Senza. 

International 

We sell Senza in Europe and Australia through a combination of our direct sales force and a network of sales 

agents and independent distributors. We began our direct sales operations in the United Kingdom in late 2010 and to 
date have expanded our direct sales operations to Austria, Australia, Belgium, Germany, Luxembourg, Norway, 
Sweden and Switzerland. We utilize sales agents and independent distributors to sell in an additional seven 
countries. 

Competition 

We compete in the SCS market for chronic pain. We also compete with spine surgeries, in particular re-
operations. Currently, our major competitors are Medtronic, Boston Scientific and Abbott Laboratories through its 
acquisition of St. Jude Medical, who have obtained regulatory approval for SCS systems. We believe that the 
primary competitive factors in the market are: 

 

 

 

 

 

 

 

 

 

 

Sales force experience and access. 

Published clinical efficacy data. 

Product support and service. 

Effective marketing and education. 

Company brand recognition. 

Clinical research leadership. 

Technological innovation, product enhancements and speed of innovation. 

Pricing and reimbursement. 

Product reliability, safety and durability. 

Ease of use. 

12 

 
 

Physician advocacy and support. 

Many of our competitors have greater capital resources, more established operations, longer commercial 

histories and more extensive relationships with physicians. They also have wider product offerings within 
neuromodulation and in other product categories, providing them with greater supplier power and with more 
opportunities to interact with stakeholders involved in purchasing decisions. We also face competition to recruit and 
retain qualified sales and other personnel. 

We expect our competitors to launch new products and release additional clinical evidence within the next few 

years. For example, Abbott Laboratories, by virtue of its recent acquisition of St. Jude Medical, Inc., recently 
received FDA approval for a SCS system that offers an alternate low frequency waveform called BurstDR, and in 
February 2016, the company gained approval for a neuromodulation system that stimulates the dorsal root ganglion 
for treatment of focal pain and complex regional pain syndrome, in each case, using pivotal clinical studies for each 
therapy to support the FDA approval process.  Medtronic is performing studies to collect data on existing SCS 
products for back pain and also testing their high density programming approach. Additionally, Boston Scientific 
has commenced a randomized clinical trial of a high-frequency SCS therapy in their Accelerate study and of a sub-
threshold therapy through their Whisper study. Additionally, there are a number of emerging competitors at various 
stages of development. Stimwave has developed and is starting to commercialize a minimally invasive stimulation 
system that employs an externally worn power source and radio frequency transmitter.  Saluda is developing and 
testing a low frequency closed loop system for the treatment of chronic pain.  In November 2015, Nuvectra, a 
company that was spun-off from Greatbatch, received FDA approval for its SCS system, which is similar to many of 
the other traditional SCS systems currently on the market. 

Intellectual Property 

We actively seek to protect the intellectual property and proprietary technology that we believe is important to 

our business, which includes seeking and maintaining patents covering our technology and products, proprietary 
processes and any other inventions that are commercially or strategically important to the development of our 
business. We also rely upon trademarks to build and maintain the integrity of our brand, and we seek to protect the 
confidentiality of trade secrets that may be important to the development of our business. For more information, 
please see “Risk Factors—Risks Related to Intellectual Property.” 

Patents, Trademarks and Proprietary Technology 

As of December 31, 2016, we owned 132 issued patents globally, of which 83 were issued U.S. utility patents, 

2 were issued U.S. design patents, 23 were issued Australian utility patents, one was an Australian design patent, 9 
were issued European utility patents, one was a European design patent, 5 were issued German Utility Models, 3 
were issued Japanese patents, one was an issued Korean utility patent, one was an issued Korean design patent, two 
were issued Chinese utility patents and one was an issued Chinese design patent. In general, our patents cover SCS 
systems that are configured to generate non-paresthesia producing therapy signals at frequencies between 1,500 Hz 
to 100,000 Hz, as well as additional aspects, algorithms and components of the Senza system and HF10 therapy. As 
of December 31, 2016, we held 101 patent applications pending globally, of which 53 were patent applications 
pending in the United States, and 48 were patent applications pending across Europe, Australia, Canada, Japan, 
China and Korea. We also have an exclusive license from the Mayo Foundation to two U.S. issued patents and two 
U.S. pending patent applications. All of our current issued patents are projected to expire between 2028 and 2035. 

As of December 31, 2016, our trademark portfolio contained 16 trademark registrations, of which there were 4 

U.S. trademark registrations, 4 Australian trademark registrations, 4 European trademark registrations, 2 Japanese 
trademark registrations, one Swiss trademark registration and one Turkish trademark registration.  Our trademark 
portfolio also contained 3 pending U.S. trademark applications and 6 pending foreign trademark applications. 

The term of individual patents depends on the legal term for patents in the countries in which they are granted. 

In most countries, including the United States, the patent term is generally 20 years from the earliest claimed filing 
date of a non-provisional patent application in the applicable country. We cannot assure that patents will be issued 
from any of our pending applications or that, if patents are issued, they will be of sufficient scope or strength to 

13 

 
provide meaningful protection for our technology. Notwithstanding the scope of the patent protection available to 
us, a competitor could develop treatment methods or devices that are not covered by our patents. Furthermore, 
numerous U.S. and foreign issued patents and patent applications owned by third parties exist in the fields in which 
we are developing products. Because patent applications can take many years to issue, there may be applications 
unknown to us, which applications may later result in issued patents that our existing or future products or 
proprietary technologies may be alleged to infringe. 

There has been substantial litigation regarding patent and other intellectual property rights in the medical 
device industry. In the future, we may need to engage in litigation to enforce patents issued or licensed to us, to 
protect our trade secrets or know-how, to defend against claims of infringement of the rights of others or to 
determine the scope and validity of the proprietary rights of others. Litigation could be costly and could divert our 
attention from other functions and responsibilities. Adverse determinations in litigation could subject us to 
significant liabilities to third parties, could require us to seek licenses from third parties and could prevent us from 
manufacturing, selling or using Senza, any of which could severely harm our business. 

We also rely upon trade secrets, know-how and continuing technological innovation, and may rely upon 
licensing opportunities in the future, to develop and maintain our competitive position. We seek to protect our 
proprietary rights through a variety of methods, including confidentiality agreements and proprietary information 
agreements with suppliers, employees, consultants and others who may have access to proprietary information, 
under which they are bound to assign to us inventions made during the term of their employment. 

The Mayo License 

In October 2006, we entered into a license agreement, or the Mayo License, with the Venturi Group, LLC, or 

VGL, and the Mayo Foundation for Medical Education and Research, or the Mayo Foundation, pursuant to which 
the Mayo Foundation committed to confer with us exclusively to develop products for the treatment of autonomic 
and peripheral nervous system disorders, including pain, using devices to modulate nerve signaling, and non-
exclusively to test such devices, and VGL committed to confer with us non-exclusively to develop such devices, and 
exclusively to test such devices. These commitments to confer expired in January 2011. We were granted a 
worldwide license to make, use, sell, offer for sale, and import products incorporating or using the know-how 
developed for and provided to us by the Mayo Foundation or VGL in the course of such development and testing 
activities, exclusively for product development and non-exclusively for product testing. Pursuant to the Mayo 
License, we are obligated to pay royalties in the low single digits to the Mayo Foundation, on a country-by-country 
and product-by-product basis, based on a percentage of net sales of licensed products, subject to reduction under 
certain circumstances. We are also required under the Mayo License to use commercially reasonable efforts to 
research, develop and commercialize licensed products. 

The Mayo License terminates upon the expiration of (1) the last to expire of the licensed patents or (2) our 

obligation to pay royalties, whichever is later. We, the Mayo Foundation or VGL may terminate the Mayo License 
upon 60 days’ notice of a party’s material breach if such breach remains uncured after such 60-day period.  

Manufacturing and Supply 

We rely upon third-party suppliers for the manufacture and assembly of our Senza SCS system and its 
components, some of which are single- or sole-sources of the relevant product component. We have not yet 
identified and qualified second-source replacements for several of our critical single-source suppliers. Thus, in the 
event that our relationship with any of our single- or sole-source suppliers terminates in the future, we may have 
difficulty maintaining sufficient production of our products at the standards we require. Where practicable, we seek 
out and validate second-source manufacturers for our single-source components. We believe that existing third-party 
facilities will be adequate to meet our current and anticipated manufacturing needs. We do not currently plan to 
manufacture the Senza SCS system components ourselves. 

We believe our manufacturing operations, and those of our suppliers, are in compliance with regulations 
mandated by the FDA. Manufacturing facilities that produce medical devices or their component parts intended for 
distribution world-wide are subject to regulation and periodic unannounced inspection by the FDA and other 
domestic and international regulatory agencies. In the United States, we are required to manufacture any products 

14 

 
that we sell in compliance with the FDA’s Quality System Regulation, or QSR, which covers the methods used in, 
and the facilities used for, the design, testing, control, manufacturing, labeling, quality assurance, packaging, storage 
and shipping of our products. In international markets, we are required to obtain and maintain various quality 
assurance and quality management certifications. We have obtained the following international certifications: 
Quality Management System ISO13485, Full Quality Assurance Certification for the design and manufacture of 
spinal cord stimulator systems and accessories and a Design Examination certificate for Implantable Pulse Generator 
and Accessories. We are required to demonstrate continuing compliance with applicable regulatory requirements to 
maintain these certifications and will continue to be periodically inspected by international regulatory authorities for 
certification purposes. 

Our material supply contracts are as follows: 

Pro-Tech Design and Manufacturing 

In July 2014, we entered into a new supply agreement with Pro-Tech Design and Manufacturing, Inc., or Pro-

Tech, pursuant to which Pro-Tech, as a single-source supplier, conducts the inspection, labeling, packaging and 
sterilization of our Senza SCS system. Our supply agreement is scheduled to expire in July 2019, unless terminated 
earlier. We may terminate the agreement without cause upon six months’ prior written notice, and Pro-Tech may 
terminate without cause upon 18 months’ prior written notice. In addition, we and Pro-Tech have the right to 
terminate the agreement upon 30 days’ prior written notice in the event of the other party’s material breach that 
remains uncured at the end of such 30-day period. 

Stellar Technologies 

On July 1, 2009, we entered into a manufacturing agreement with Stellar Technologies, Inc., or Stellar, our 
single-source supplier of our percutaneous leads, percutaneous lead extenders and surgical leads for our neurological 
stimulator products. On June 30, 2014, the agreement’s initial term expired, and the agreement automatically 
renewed for the first time. On July 1, 2014, we entered into a first amendment to the manufacturing agreement with 
Stellar, which provides for an additional five year term commencing from the date of the amendment, after which 
the agreement automatically renews for successive one-year terms unless either party provides written notice of 
intent not to renew at least 30 days before the expiration of the then-current term. On January 28, 2016, we entered 
into a second amendment to this agreement, which provides for the purchase of certain supplementary products 
pursuant to the agreement. We refer to the manufacturing agreement as amended by the first and second 
amendments as the Stellar Agreement. 

Either we or Stellar may terminate the Stellar Agreement at will upon one year’s advance notice, subject to 
certain remaining rights and payment obligations, including an early cancellation fee payable by us to Stellar. We 
may also terminate the Stellar Agreement if Stellar is unable to perform its obligations under the Stellar Agreement 
for 60 days or more, or if Stellar is unwilling to perform its obligations under the Stellar Agreement and does not 
cure such defect within 60 days’ of our providing written notice to cure. Stellar may terminate the Stellar Agreement 
in the event of our default of certain specified obligations, including our payment obligations, material violation of a 
warranty or law, our material breach, and our insolvency. 

CCC Supply Agreement 

We rely upon C.C.C. Del Uruguay S.A., or CCC, a subsidiary of Greatbatch Ltd., as one of our manufacturers 

of our IPGs. In April 2012, we entered into our original supply agreement with CCC, which we later amended in 
March 2013, June 2014 and November 2016. On November 15, 2016, we entered into a new multi-year supply 
agreement with CCC, pursuant to which CCC agreed to a revised arrangement with regard to the manufacture and 
supply of our IPGs. The agreement is effective as of November 11, 2016 and, pursuant to its terms, terminated our 
existing supply agreement with CCC entered into on March 13, 2015. 

Pursuant to the terms of the agreement, CCC agreed to manufacture and supply our IPGs during the term of 

the agreement. For the first three years of the term of the agreement, we are obligated to purchase from CCC 
specified minimum purchase quantities of Model 1500 IPGs. At such time as we and the FDA approves the Model 
2000 IPG and related manufacturing processes and facility, we will become obligated to purchase from CCC 

15 

 
specified minimum purchase quantities of Model 2000 IPGs. The foregoing specified minimum purchase 
obligations are subject to certain exceptions and reductions in the event of supply failures, shortages and product 
defects. 

The agreement continues for ten years unless terminated earlier. The term of the agreement automatically 

renews for additional two-year terms unless one party provides the other party with written notice of termination at 
least one year prior to the end of the initial term or the applicable renewal period. In the event of a change of control 
of CCC, the agreement may be terminated by us upon three years’ written notice to CCC, provided that such notice 
period shall be one year in the event CCC is acquired by certain competitors to us. In addition, the agreement may 
be terminated by mutual agreement of the parties, or by either party, with written notice, upon the other party’s 
cessation of business or other termination of its business operations, uncured material breach or insolvency of the 
other party. Upon termination of the agreement, CCC shall, subject to certain exceptions and unless otherwise 
agreed to by the parties, fulfill all purchase orders placed by us and accepted by CCC prior to the effective date of 
termination. 

The agreement contains, among other provisions, customary representations and warranties by the parties, 
ordering and payment and shipping terms, customary provisions with respect to the ownership of any intellectual 
property created during the term of the agreement, certain indemnification rights in favor of both parties, limitations 
of liability and customary confidentiality provisions. 

EaglePicher Medical Power Supply Agreement 

In April 2009, we entered into a product supply and development agreement with EaglePicher Medical 
Power LLC, or EaglePicher, our single-source supplier of the batteries and related products for our IPG. Pursuant to 
the agreement, EaglePicher must use its best efforts to supply these batteries and related products in sufficient 
quantity to meet our demand. The agreement also provides that, upon our written request, EaglePicher will conduct 
development of a modified version of these products to our specifications, if we so desire. The initial term of our 
supply agreement with EaglePicher expired in November 2010, and the term had been automatically renewing for 
successive one-year periods. 

In March 2015, we entered into a first amendment to the product supply and development agreement with 
EaglePicher. The amendment commits us to specified minimum purchase amounts over the course of the term of the 
agreement and adjusts EaglePicher’s production capacity and facilities commitments under the agreement as well as 
certain pricing, purchasing, delivery and cancellation terms. The amendment also extends the term of the agreement 
to December 31, 2019, with an additional two-year automatic renewal period unless we or EaglePicher provides 
notice of its intent not to renew prior to the commencement of such renewal term. We have also agreed, subject to 
certain conditions, to purchase minimum quantities of product. The amendment further provides us with the right to 
place a final order with EaglePicher following termination of the agreement, as amended and modifies certain 
warranty and assignment terms and the parties’ limitations of liability. 

In November 2015, we entered into a second amendment to the agreement, which increased our pre-existing 

specified minimum purchase amounts and increased EaglePicher’s production capacity commitments under the 
agreement, as well as specifying certain purchasing and purchase order protocols.  The amendment obligated 
EaglePicher to establish and qualify an additional battery production operation and commits us to fund 
approximately $1.0 million of such production operation paid in three milestone installments.  The amendment also 
establishes EaglePicher as our exclusive battery supplier through the initial five-year term of the agreement, ending 
December 31, 2019. 

Vention Supply Agreement 

In December 2015, we entered into a Manufacturing and Supply Agreement with Vention Medical Design and 

Development, Inc., or Vention, pursuant to which Vention agreed to manufacture and supply our IPGs.  We are 
obligated to purchase from Vention specified minimum purchase quantities of IPGs for the duration of the Vention 
agreement. 

16 

 
The agreement continues for five years unless terminated earlier. The term of the agreement automatically 

renews for additional one-year terms unless one party provides the other party with written notice of termination at 
least one year prior to the end of the applicable renewal period. The agreement may be terminated by us for any 
reason upon 180 days’ written notice to Vention. In addition, the agreement may be terminated by mutual agreement 
of the parties, or by either party, with written notice, upon uncured material breach or insolvency of the other party. 
Upon termination of the agreement, Vention shall, upon our request, manufacture an additional 24 months of 
continuous supply of IPGs based on the preceding forecast average or such other amount as agreed upon by the 
parties. 

Other Suppliers 

We also have other suppliers, including some sole-source suppliers, for certain of our components, with whom 

we do not have agreements. 

Product Liability and Insurance 

The manufacture and sale of our products subjects us to the risk of financial exposure to product liability 

claims. Our products are used in situations in which there is a risk of serious injury or death. We carry insurance 
policies which we believe to be customary for similar companies in our industry. We cannot assure you that these 
policies will be sufficient to cover all or substantially all losses that we experience. 

We endeavor to maintain executive and organization liability insurance in a form and with aggregate coverage 

limits that we believe are adequate for our business purposes, but our coverage limits may prove not to be adequate 
in some circumstances. 

Government Regulations 

United States 

Our products and operations are subject to extensive and rigorous regulation by the FDA under the Federal 
Food, Drug, and Cosmetic Act, or FFDCA, and its implementing regulations, guidances, and standards. The FDA 
regulates the research, testing, manufacturing, safety, labeling, storage, recordkeeping, promotion, distribution, and 
production of medical devices in the United States to ensure that medical products distributed domestically are safe 
and effective for their intended uses. The FDA also regulates the export of medical devices manufactured in the 
United States to international markets. Any violations of these laws and regulations could result in a material 
adverse effect on our business, financial condition and results of operations. In addition, if there is a change in law, 
regulation or judicial interpretation, we may be required to change our business practices, which could have a 
material adverse effect on our business, financial condition and results of operations. 

Under the FFDCA, medical devices are classified into one of three classes—Class I, Class II or Class III—

depending on the degree of risk associated with each medical device and the extent of control needed to ensure 
safety and effectiveness. 

Class I devices are those for which safety and effectiveness can be assured by adherence to FDA’s “general 

controls” for medical devices, which include compliance with the applicable portions of the QSR facility registration 
and product listing, reporting of adverse medical events, and appropriate, truthful and non-misleading labeling, 
advertising, and promotional materials. Some Class I devices also require premarket clearance by the FDA through 
the 510(k) premarket notification process described below. 

Class II devices are subject to FDA’s general controls, and any other “special controls” deemed necessary by 
FDA to ensure the safety and effectiveness of the device. Premarket review and clearance by the FDA for Class II 
devices is accomplished through the 510(k) premarket notification procedure, though certain Class II devices are 
exempt from this premarket review process. When a 510(k) is required, the manufacturer must submit to the FDA a 
premarket notification submission demonstrating that the device is “substantially equivalent” to a legally marketed 
device, which in some cases may require submission of clinical data. A legally marketed device is defined by statute 
to mean a device that was legally marketed prior to May 28, 1976, the date upon which the Medical Device 

17 

 
Amendments of 1976 were enacted, or another commercially available, similar device that was cleared through the 
510(k) process. Unless a specific exemption applies, 510(k) premarket notification submissions are subject to user 
fees. If the FDA determines that the device, or its intended use, is not substantially equivalent to a legally marketed 
device, the FDA will place the device, or the particular use of the device, into Class III, and the device sponsor must 
then fulfill much more rigorous premarketing requirements in the form of a premarket approval, or PMA. 

A Class III device includes devices deemed by the FDA to pose the greatest risk such as life-supporting or 

life-sustaining devices, or implantable devices, in addition to a device that has a new intended use or utilizes 
advanced technology that is not substantially equivalent to that of a legally marketed device. The safety and 
effectiveness of Class III devices cannot be assured solely by general and special controls. These devices almost 
always require formal clinical studies to demonstrate safety and effectiveness. 

Submission and FDA approval of a PMA application is required before marketing of a Class III device can 

proceed. 

PMA Approval 

The Senza SCS system is a Class III device subject to review and approval through the PMA pathway. PMA 
applications must be supported by, among other things, valid scientific evidence, which typically requires extensive 
data, including technical, preclinical, clinical and manufacturing data, to demonstrate to the FDA’s satisfaction the 
safety and effectiveness of the device. A PMA application must also include, among other things, a complete 
description of the device and its components, a detailed description of the methods, facilities and controls used to 
manufacture the device and proposed labeling. As with 510(k) submissions, unless subject to an exemption, PMA 
submissions are subject to user fees. 

The FDA has 45 days from its receipt of a PMA to determine whether the application will be accepted for 
filing based on the agency’s threshold determination that it is sufficiently complete to permit substantive review. 
Once the submission is accepted for filing, the FDA begins an in-depth review. The FDA, by statute and by 
regulation, has 180-days to review an “accepted” PMA application, although the review of an application more often 
occurs over a significantly longer period of time, and can take up to several years. During this review period, the 
FDA may request additional information or clarification of information already provided. In addition, the FDA will 
conduct a pre-approval inspection of the applicant and/or its third-party manufacturers’ or suppliers’ manufacturing 
facility or facilities to ensure compliance with the QSR, which requires manufacturers to follow design, testing, 
control, documentation and other quality assurance procedures. 

The timing of FDA review of an initial PMA application can vary substantially and, in some cases, require 

several years to complete. The FDA can delay, limit, or deny approval of a PMA application for many reasons, 
including: 

 

 

 

it is not demonstrated that there is reasonable assurance that the device is safe or effective under the 
conditions of use prescribed, recommended or suggested in the proposed labeling; 

the data from preclinical studies and clinical trials may be insufficient; and 

the manufacturing process, methods, controls or facilities used for the manufacture, processing, packing 
or installation of the device do not meet applicable requirements. 

If the FDA evaluations of both the PMA application and the manufacturing facilities are favorable, the FDA 
will either issue an approval letter or an approvable letter, which usually contains a number of conditions that must 
be met in order to secure final approval of the PMA. If the FDA’s evaluation of the PMA or manufacturing facilities 
is not favorable, the FDA will deny approval of the PMA or issue a not approvable letter. A not approvable letter 
will outline the deficiencies in the application and, where practical, will identify what is necessary to make the PMA 
approvable. The FDA may also determine that additional clinical trials are necessary, in which case the PMA 
approval may be delayed for several months or years while the trials are conducted and the data is then submitted in 
an amendment to the PMA. Once granted, PMA approval may be withdrawn by the FDA if compliance with post 
approval requirements, conditions of approval or other regulatory standards is not maintained or problems are 

18 

 
identified following initial marketing.  In May 2015, we received approval for our PMA application for the Senza 
SCS system. 

Approval by the FDA of new PMA applications or PMA supplements may be required for modifications to 
the manufacturing process, labeling, device specifications, materials or design of a device that is approved through 
the PMA process. PMA supplements often require submission of the same type of information as an initial PMA 
application, except that the supplement is limited to information needed to support any changes from the device 
covered by the original PMA application and may not require as extensive clinical data.  For example, if we seek 
approval to expand the label of Senza to include additional pain indications, we anticipate that we will be required to 
submit and receive approval for a PMA supplement. 

Clinical Studies 

In the United States, human clinical trials intended to support medical device clearance or approval require 

compliance with the FDA’s investigational device exemption, or IDE, regulations. For a device that presents a 
“significant risk” to human health, the device sponsor is required to file an IDE application with the FDA and obtain 
IDE approval prior to commencing the human clinical trial, as well as obtain approval of an Institutional Review 
Board, or IRB, at each institution where the study will be conducted. If the device is considered a “non-significant 
risk,” IDE approval from FDA is not required. Instead, only approval from the IRB overseeing the investigation at 
each clinical trial site is required, though the sponsor must still comply with abbreviated IDE requirements, such as 
protection of human subjects and informed consent. Human clinical studies are generally required in connection 
with approval of Class III devices and may be required for Class I and II devices. The FDA or the IRB at each 
institution at which a clinical trial is being performed may suspend a clinical trial at any time for various reasons, 
including a belief that the subjects are being exposed to an unacceptable health risk. 

Continuing Regulation 

After the FDA permits a device to enter commercial distribution, numerous regulatory requirements apply. 

These include: compliance with the QSR, which requires manufacturers to follow elaborate design, testing, control, 
documentation and other quality assurance procedures during the manufacturing process; labeling regulations; the 
FDA’s general prohibition against promoting products for unapproved or “off-label” uses; the reports of Corrections 
and Removals regulation, which requires manufacturers to report recalls and field actions to the FDA if initiated to 
reduce a risk of health posed by the device or to remedy a violation of the Federal Food, Drug and Cosmetic Act; 
and the Medical Device Reporting regulation, which requires that manufacturers report to the FDA if their device 
may have caused or contributed to a death or serious injury or malfunctioned in a way that would likely cause or 
contribute to a death or serious injury if it were to reoccur. Manufacturers are also required to register and list their 
devices with the FDA, based on which the FDA will conduct inspections to ensure continued compliance with 
applicable regulatory requirements. 

The FDA has broad post-market and regulatory and enforcement powers. Failure to comply with the 
applicable U.S. medical device regulatory requirements could result in, among other things, warning letters; fines; 
injunctions; consent decrees; civil penalties; repairs, replacements or refunds; recalls, corrections or seizures of 
products; total or partial suspension of production; the FDA’s refusal to grant future premarket clearances or 
approvals; withdrawals or suspensions of current product applications; and criminal prosecution. If any of these 
events were to occur, they could have a material adverse effect on our business, financial condition and results of 
operations. 

International 

Our international sales are subject to regulatory requirements in the countries in which our products are sold. 

The regulatory review process varies from country to country and may in some cases require the submission of 
clinical data. In addition, the FDA must be notified of, or approve the export to certain countries of devices that 
require a PMA, and not yet approved in the United States. 

19 

 
In the European Economic Area, or EEA (which is comprised of the 28 Member States of the EU plus 
Norway, Liechtenstein and Iceland), we need to comply with the requirements of the EU Active Implantable 
Medical Devices Directive, or AIMDD, and appropriately affix the CE Mark on our products to attest to such 
compliance. To achieve compliance, our products must meet the “Essential Requirements” laid down in Annex I of 
the AIMDD relating to safety and performance. To demonstrate compliance with the Essential Requirements and 
obtain the right to affix the CE mark we must undergo a conformity assessment procedure, which varies according 
to the type of medical device and its classification. Except for low risk medical devices (Class I with no measuring 
function and which are not sterile), where the manufacturer can issue an EC Declaration of Conformity based on a 
self-assessment of the conformity of its products with the Essential Requirements, a conformity assessment 
procedure requires the intervention of a Notified Body, which is an organization designated by a competent 
authority of an EEA country to conduct conformity assessments. Depending on the relevant conformity assessment 
procedure, the Notified Body would audit and examine the Technical File and the quality system for the 
manufacture, design and final inspection of our devices. The Notified Body issues a CE Certificate of Conformity 
following successful completion of a conformity assessment procedure conducted in relation to the medical device 
and its manufacturer and their conformity with the Essential Requirements. This Certificate entitles the manufacturer 
to affix the CE mark to its medical devices after having prepared and signed a related EC Declaration of 
Conformity. The assessment of the conformity of Senza has been certified by our Notified Body (the British 
Standards Institution, or BSI). 

As a general rule, demonstration of conformity of medical devices and their manufacturers with the Essential 

Requirements must be based, among other things, on the evaluation of clinical data supporting the safety and 
performance of the products during normal conditions of use. Specifically, a manufacturer must demonstrate that the 
device achieves its intended performance during normal conditions of use and that the known and foreseeable risks, 
and that any adverse events, are minimized and acceptable when weighed against the benefits of its intended 
performance, and that any claims made about the performance and safety of the device (e.g., product labeling and 
instructions for use) are supported by suitable evidence. This assessment must be based on clinical data, which can 
be obtained from (1) clinical studies conducted on the devices being assessed, (2) scientific literature from similar 
devices whose equivalence with the assessed device can be demonstrated or (3) both clinical studies and scientific 
literature. With respect to active implantable medical devices or Class III devices, the manufacturer must conduct 
clinical studies to obtain the required clinical data, unless reliance on existing clinical data from equivalent devices 
can be justified. The conduct of clinical studies in the EEA is governed by detailed regulatory obligations. These 
may include the requirement of prior authorization by the competent authorities of the country in which the study 
takes place and the requirement to obtain a positive opinion from a competent Ethics Committee. This process can 
be expensive and time-consuming. Additionally, Senza must continue to comply with the requirements of certain 
EU Directives. 

We are subject to continued surveillance by our Notified Body and will be required to report any serious 

adverse incidents to the appropriate authorities. We also must comply with additional requirements of individual 
countries in which our products are marketed. 

The assessment of the conformity of Senza with the AIMDD and the Radio and Telecommunications 

Terminal (R&TTE) Directive has been certified by the BSI. 

In September 2012, the European Commission published proposals for the revision of the EU regulatory 

framework for medical devices. The proposal would replace the Medical Devices Directive and the Active 
Implantable Medical Devices Directive with two new regulations; the Medical Devices Regulation and the In-Vitro 
Diagnostic Medical Devices Regulation. Unlike the directives, which must be implemented into the national laws of 
the EEA member States, the regulations would be directly applicable, i.e., without the need for adoption of EEA 
member State laws implementing them, in all EEA Member States and are intended to eliminate current differences 
in the regulation of medical devices among EEA member States. 

The European Parliament adopted its position on the European Commission’s proposals in first reading in 
April 2014 and the European Council agreed on its general approach in October 2015. Interinstitutional negotiations 
between the European Council, Parliament and Commission concluded with an agreement on a revised version of 
the proposals in May 2016. Both proposals are now undergoing legal-linguistic revision. The formal first reading of 
the Council is expected early this year, followed by a plenary vote in Parliament at second reading, which would 

20 

 
lead to the final adoption of the two regulations in the first quarter of 2017. The Medical Devices Regulation will 
however only become applicable three years after publication while the In-Vitro Diagnostic Medical Devices 
Regulation will only become applicable five years after publication. Once applicable, the new regulations will 
among other things: 

 

 

 

 

 

strengthen the rules on placing devices on the market and reinforce surveillance once they are available; 

establish explicit provisions on manufacturers' responsibilities for the follow-up of the quality, 
performance and safety of devices placed on the market;  

improve the traceability of medical devices throughout the supply chain to the end-user or patient 
through a unique identification number;  

set up a central database to provide patients, healthcare professionals and the public with comprehensive 
information on products available in the EU;  

strengthened rules for the assessment of certain high-risk devices, such as implants, which may have to 
undergo an additional check by experts before they are placed on the market.  

Other Regulations 

We are also subject to healthcare fraud and abuse regulation in the jurisdictions in which we will conduct our 

business. These laws include, without limitation, applicable anti-kickback, false claims, physician sunshine and 
patient privacy and security laws and regulations. 

Anti-Kickback Statute: The federal Anti-Kickback Statute prohibits, among other things, persons or entities 

from knowingly and willfully soliciting, offering, receiving or paying any remuneration, directly or indirectly, 
overtly or covertly, in cash or in kind, in exchange for or to induce either the referral of an individual for, or the 
purchase, lease, order or recommendation of, any good, facility, item or service for which payment may be made, in 
whole or in part, under federal healthcare programs such as Medicare and Medicaid. The federal Anti-Kickback 
Statute is broad and prohibits many arrangements and practices that are lawful in businesses outside of the 
healthcare industry. The term “remuneration” includes kickbacks, bribes, or rebates and also has been broadly 
interpreted to include anything of value, including for example, gifts, discounts, the furnishing of supplies or 
equipment, credit arrangements, payments of cash, waivers of payments, ownership interests and providing anything 
at less than its fair market value. There are a number of statutory exceptions and regulatory safe harbors protecting 
certain business arrangements from prosecution under the federal Anti-Kickback Statute. These statutory exceptions 
and safe harbors set forth provisions that, if all their applicable requirements are met, will assure healthcare 
providers and other parties that they may not be prosecuted under the federal Anti-Kickback Statute. The failure of a 
transaction or arrangement to fit precisely within one or more applicable statutory exceptions or safe harbors does 
not necessarily mean that it is illegal or that prosecution will be pursued. However, conduct and business 
arrangements that do not fully satisfy all requirements of an applicable safe harbor may result in increased scrutiny 
by government enforcement authorities and will be evaluated on a case-by-case basis based on a cumulative review 
of all of its facts and circumstances. Further, a person or entity does not need to have actual knowledge of the statute 
or specific intent to violate it. In addition, the government may assert that a claim including items or services 
resulting from a violation of the federal Anti-Kickback Statute constitutes a false or fraudulent claim for purposes of 
the federal civil False Claims Act which is discussed below. Penalties for violations of the Anti-Kickback Statute 
include, but are not limited to, criminal, civil and/or administrative penalties, damages, fines, disgorgement, 
individual imprisonment, possible exclusion from Medicare, Medicaid and other federal healthcare programs, and 
the curtailment or restructuring of operations. 

Federal Civil False Claims Act: The federal civil False Claims Act prohibits, among other things, persons or 
entities from knowingly presenting or causing to be presented a false or fraudulent claim to, or the knowing use of 
false statements to obtain payment from or approval by, the federal government. In addition, private individuals 
have the ability to bring actions under the civil False Claims Act in the name of the government alleging false and 
fraudulent claims presented to or paid by the government (or other violations of the statutes) and to share in any 
amounts paid by the entity to the government in fines or settlement. Such suits, known as qui tam actions, have 
increased significantly in the healthcare industry in recent years. Manufacturers can be held liable under these laws 
if they are deemed to “cause” the submission of false or fraudulent claims by, for example, providing inaccurate 

21 

 
billing or coding information to customers or promoting a product off-label. Penalties for a federal civil False 
Claims Act violation include three times the actual damages sustained by the government, plus mandatory civil 
penalties that range, as of August 1, 2016, from approximately $10,781 to $21,563 for each separate false claim, the 
potential for exclusion from participation in federal healthcare programs and criminal liability.  

Health Insurance Portability and Accountability Act of 1996: The federal Health Insurance Portability and 

Accountability Act, or HIPAA, created several new federal crimes, including healthcare fraud and false statements 
relating to healthcare matters. The healthcare fraud statute prohibits knowingly and willfully executing, or 
attempting to execute, a scheme to defraud any healthcare benefit program, including private third-party payors. The 
false statements statute prohibits knowingly and willfully falsifying, concealing or covering up a material fact or 
making any materially false, fictitious or fraudulent statement in connection with the delivery of or payment for 
healthcare benefits, items or services. 

In addition, HIPAA and its implementing regulations established uniform standards for certain covered 
entities, which are healthcare providers, health plans and healthcare clearinghouses, as well as their business 
associates, governing the conduct of specified electronic healthcare transactions and protecting the security and 
privacy of protected health information. HIPAA, as amended by the Health Information Technology for Economic 
and Clinical Health Act, created four new tiers of civil monetary penalties and gave state attorneys general new 
authority to file civil actions for damages or injunctions in federal courts to enforce the federal HIPAA laws and 
seek attorneys’ fees and costs associated with pursuing federal civil actions. 

EU Data Protection Laws: We are subject to laws and regulations in non-U.S. countries covering data privacy 

and the protection of health-related and other personal information. EU member states and other jurisdictions have 
adopted data protection laws and regulations, which impose significant compliance obligations. Laws and 
regulations in these jurisdictions apply broadly to the collection, use, storage, disclosure and security of personal 
information that identifies or may be used to identify an individual, such as names, contact information and sensitive 
personal data such as health data. These laws and regulations are subject to frequent revisions and differing 
interpretations, and have generally become more stringent over time.  

For example, the EU Data Protection Directive, as implemented into national laws by the EU member states, 

imposes strict obligations and restrictions on the processing of personal data. The new EU-wide General Data 
Protection Regulation, or GDPR, entered into force in May 2016 and will become applicable on May 25, 2018, 
replacing the current data protection laws of each EU member state. The GDPR will implement more stringent 
operational requirements for processors and controllers of personal data, including, for example, expanded 
disclosures about how personal information is to be used, limitations on retention of information, increased 
requirements pertaining to health data and pseudonymised (i.e., key-coded) data, mandatory data breach notification 
requirements and higher standards for data controllers to demonstrate that they have obtained valid consent for 
certain data processing activities. The GDPR provides that EU member states may make their own further laws and 
regulations limiting the processing of genetic, biometric or health data, which could limit our ability to use and share 
personal data or could cause our costs could increase, and harm our business and financial condition.  

We are also subject to evolving EU laws on data export, as we may transfer personal data from the EU to 

other jurisdictions. For example, in 2015, the Court of Justice of the European Union invalidated the U.S.-EU Safe 
Harbor framework regarding the transfer of personal data from the EU to the U.S. EU and U.S. negotiators agreed in 
February 2016 to a new framework, the Privacy Shield, which would replace the Safe Harbor framework. However, 
there is currently litigation against this framework as well as litigation challenging other EU mechanisms for 
adequate data transfers (e.g. the standard contractual clauses), and it is uncertain whether the Privacy Shield 
framework and/or the standard contractual clauses will be similarly invalidated by the EU courts. We rely on a 
mixture of mechanisms to transfer data to from our EU business to the U.S., and could be impacted by changes in 
law as a result of the current challenges to these mechanisms in the European courts. 

In recent years, U.S. and European lawmakers and regulators have expressed concern over electronic 

marketing and the use of third-party cookies, web beacons and similar technology for online behavioral advertising. 
In the EU, informed consent is required for the placement of a cookie on a user’s device. The current EU laws that 
cover the use of cookies and similar technology and marketing online or by electronic means are under reform. A 
draft of the new ePrivacy Regulation was announced on January 10, 2017 and is targeted to become applicable on 

22 

 
May 25, 2018 (alongside the GDPR). Unlike the current ePrivacy Directive, this will be directly implemented into 
the laws of each of the EU member States, without the need for further enactment. When implemented, the ePrivacy 
Regulation is expected to alter rules on third-party cookies, web beacons and similar technology for online 
behavioral advertising and to impose stricter requirements on companies using these tools.  The draft also extends 
the strict opt-in marketing rules with limited exceptions to business to business communications, and significantly 
increases penalties. 

Any failure or perceived failure by us to comply with privacy or security laws, policies, legal obligations or 

industry standards or any security incident that results in the unauthorized release or transfer of personally 
identifiable information may result in governmental enforcement actions and investigations including by European 
Data Protection Authorities, fines and penalties (for example, of up to 20,000,000 Euros or up to 4% of the total 
worldwide annual turnover of the preceding financial year (whichever is higher) under the GDPR and draft ePrivacy 
Regulation), litigation and/or adverse publicity, including by consumer advocacy groups, and could cause our 
customers to lose trust in us, which could have an adverse effect on our reputation and business. Such failures could 
have a material adverse effect on our financial condition and operations. If the third parties we work with violate 
applicable laws, contractual obligations or suffer a security breach, such violations may also put us in breach of our 
obligations under privacy laws and regulations and/or could in turn have a material adverse effect on our business. 

The Federal Physician Payments Sunshine Act: The federal Physician Payments Sunshine Act requires certain 

manufacturers of drugs, devices, biologics and medical supplies for which payment is available under Medicare, 
Medicaid or the Children’s Health Insurance Program, with certain exceptions, to report annually to CMS 
information related to “payments or other transfers of value” made to physicians (defined to include doctors, 
dentists, optometrists, podiatrists and chiropractors) and teaching hospitals, and to report annually to CMS certain 
ownership and investment interests held by physicians and their immediate family members.  

Analogous State and Foreign Law Equivalents:  We may be subject to state and foreign law equivalents of 
each of the above federal laws, such as anti-kickback and false claims laws which may apply to items or services 
reimbursed by any third-party payor, including commercial insurers; state laws that require device companies to 
comply with the industry’s voluntary compliance guidelines and the applicable compliance guidance promulgated 
by the federal government or otherwise restrict payments that may be made to healthcare providers and other 
potential referral sources; state laws that require device manufacturers to report information related to payments and 
other “transfers of value” to physicians and other healthcare providers or marketing expenditures; and state laws 
governing the privacy and security of health information in certain circumstances, many of which differ from each 
other in significant ways and may not have the same effect, thus complicating compliance efforts. 

Healthcare Reform: In March 2010 the Affordable Care Act, or the ACA, was signed into law, which has the 

potential to substantially change healthcare financing and delivery by both governmental and private insurers, and 
significantly impact the medical device industry. The Affordable Care Act impacted existing government healthcare 
programs and resulted in the development of new programs. The Affordable Care Act’s provisions of importance 
include, but are not limited to, a deductible 2.3% excise tax on any entity that manufactures or imports medical 
devices offered for sale in the United States, with limited exceptions, effective January 1, 2013. In December 2015, 
Former President Obama signed into law the Consolidated Appropriations Act, 2016, which included a two-year 
moratorium on the medical device excise tax such that medical device sales in 2016 and 2017 are exempt from the 
medical device excise tax. Unless there is further legislative action, the tax will be automatically reinstated for sales 
of medical devices on or after January 1, 2018. 

In addition, other legislative changes have been proposed and adopted since the ACA was enacted. These 
changes included an aggregate reduction in Medicare payments to providers of up to 2% per fiscal year, which went 
into effect on April 1, 2013 and will remain in effect through 2025 unless additional Congressional action is taken. 
The Medicare Access and CHIP Reauthorization Act of 2015, enacted on April 16, 2015 (MACRA), repealed the 
formula by which Medicare made annual payment adjustments to physicians and replaced the former formula with 
fixed annual updates and a new system of incentive payments scheduled to begin in 2019 that are based on various 
performance measures and physicians’ participation in alternative payment models such as accountable care 
organizations. 

23 

 
There have been judicial and congressional challenges to certain aspects of the ACA. In addition, Congress 

could consider subsequent legislation to repeal or potentially replace certain elements of the ACA. Any regulatory or 
legislative developments in domestic or foreign markets that eliminates or reduces reimbursement rates for 
procedures performed with our products could harm our ability to sell our products or cause downward pressure on 
the prices of our products, either of which would affect our ability to generate the revenues necessary to support our 
business. 

The Foreign Corrupt Practices Act: The Foreign Corrupt Practices Act, or FCPA, prohibits any U.S. 
individual or business from paying, offering or authorizing payment or offering of anything of value, directly or 
indirectly, to any foreign official, political party or candidate for the purpose of influencing any act or decision of 
the foreign entity in order to assist the individual or business in obtaining or retaining business. The FCPA also 
obligates companies whose securities are listed in the United States to comply with accounting provisions requiring 
the company to maintain books and records that accurately and fairly reflect all transactions of the corporation, 
including international subsidiaries, and to devise and maintain an adequate system of internal accounting controls 
for international operations. 

The UK Bribery Act. The UK Bribery Act prohibits giving, offering or promising bribes to any person, 
including non-UK government officials and private persons, as well as requesting, agreeing to receive, or accepting 
bribes from any person. In addition, under the UK Bribery Act, companies which carry on a business or part of a 
business in the UK, as we do, may be held liable for bribes given, offered or promised to any person, including non-
UK government officials and private persons, by employees and persons associated with the company in order to 
obtain or retain business or a business advantage for the company. Liability is strict, with no element of a corrupt 
state of mind, but a defense of having in place adequate procedures designed to prevent bribery is available. 
Furthermore, under the UK Bribery Act there is no exception for facilitation payments. 

Employees 

As of December 31, 2016, we had 518 employees globally. We believe the success of our business depends, in 

part, on our ability to attract and retain qualified personnel. We are committed to developing our employees and 
providing them with opportunities to contribute to our growth and success. Our employees are not subject to a 
collective bargaining agreement, and we believe that we have good relations with our employees. 

About Us 

We were incorporated in Minnesota in March 2006 and reincorporated in Delaware in October 2006. We 
completed the initial public offering of our common stock in November 2014. Our common stock is currently listed 
on the New York Stock Exchange (NYSE) under the symbol “NVRO.” Our principal executive offices are located 
at 1800 Bridge Parkway, Redwood City, California 94065. Our telephone number is (650) 251-0005. Our website 
address is www.nevro.com. The information on, or that can be accessed through, our website is not incorporated by 
reference into this Annual Report on Form 10-K, or Annual Report, or any other filings we make with the U.S. 
Securities and Exchange Commission, or SEC. 

Available Information 

We make available on or through our website certain reports and amendments to those reports that we file 

with, or furnish to, the SEC in accordance with the Securities Exchange Act of 1934, as amended, or the Exchange 
Act. These include our Annual Reports on Form 10-K, our Quarterly Reports on Form 10-Q and our Current 
Reports on Form 8-K, and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the 
Exchange Act. We make this information available on or through our website free of charge as soon as reasonably 
practicable after we electronically file the information with, or furnish it to, the SEC. This information is also 
available by writing to us at the address on the cover of this Annual Report.  Copies of this information may be 
obtained at the SEC’s Public Reference Room at 100 F Street, NE, Washington, D.C. 20549. Information on the 
operation of the Public Reference Room may be obtained by calling the SEC at 1-800-SEC-0330. The SEC 
maintains a website that contains reports, proxy and information statements, and other information regarding our 
filings, at www.sec.gov. The information on, or that can be accessed through, our website is not incorporated by 
reference into this Annual Report or any other filings we make with the SEC. 

24 

 
ITEM 1A. RISK FACTORS 

Our business involves significant risks, some of which are described below. You should carefully consider these 
risks, as well as the other information in this Annual Report, including our financial statements and the related 
notes and “Management’s Discussion and Analysis of Financial Condition and Results of Operations.” The 
occurrence of any of the events or developments described below could harm our business, financial condition, 
results of operations and growth prospects. Additional risks and uncertainties not presently known to us or that we 
currently deem immaterial may also impair our business. 

Risks Related to our Business 

We have a history of significant losses. If we do not achieve and sustain profitability, our financial condition 
could suffer. 

We have experienced significant net losses, and have no assurance that we will achieve profitability. In May 

2015, the FDA approved our PMA to market Senza in the United States and we commenced commercial sales in the 
United States in mid-2015. We expect to continue to incur losses as we build our U.S. commercial sales force and 
continue our commercial launch in the United States, as well as continue to investigate the use of our HF10 therapy 
to treat other chronic pain conditions. We incurred net losses of $31.8 million, $67.4 million and $30.7 million for 
the years ended December 31, 2016, 2015 and 2014, respectively. As of December 31, 2016 our accumulated deficit 
was $221.2 million. Our prior losses have had, and will continue to have, an adverse effect on our stockholders’ 
equity and working capital. If our revenue grows more slowly than we anticipate, or if our operating expenses are 
higher than we expect, we may not be able to achieve profitability and our financial condition could suffer. For 
example, we have recently filed a complaint against Boston Scientific alleging patent infringement, and Boston 
Scientific Corporation followed by filing a complaint against us alleging patent infringement.  These lawsuits may 
result in substantial legal expenses.  Even if we achieve profitability in the future, we may not be able to sustain 
profitability in subsequent periods. 

We are substantially dependent on continued market acceptance in the United States for our HF10 therapy, and 
the failure of our HF10 therapy to continue to gain market acceptance would negatively impact our business. 

Since our inception, we have devoted substantially all of our efforts to the development and 

commercialization of Senza and HF10 therapy for the treatment of chronic leg and back pain. Prior to mid-2015, our 
revenue was derived nearly entirely from sales of Senza in Europe and Australia. Although we received approval of 
our PMA in May 2015, we are still in the early stages of our commercialization efforts in the United States and have 
a limited history of commercializing our product in the United States. We have incurred, and anticipate we will in 
the future incur, significant costs, including costs to continue to build our sales force in order to sustain our 
commercial sales in the United States. If we are unable to continue to achieve significant market acceptance in the 
United States, our results of operations will be adversely affected as the United States is expected to be the principal 
market for Senza. Because we do not have any other products currently in development, if we are unsuccessful in 
our continuing efforts to commercialize Senza or are unable to market Senza as a result of a quality problem, failure 
to maintain or obtain additional regulatory approvals, unexpected or serious complications or other unforeseen 
negative effects related to our HF10 therapy or the other factors discussed in these risk factors, we would lose our 
only source of revenue, and our business will be materially adversely affected. 

We also have limited experience engaging in commercial activities and limited established relationships with 

physicians and hospitals as well as third-party suppliers on whom we depend for the manufacture of our product. We 
may be unable to gain broader market acceptance in the countries in which we have already begun to commercialize 
Senza, including the United States, for a number of reasons, including: 

 

 

 

established competitors with strong relationships with customers, including physicians, hospitals and 
third-party suppliers; 

limitations in our ability to demonstrate differentiation and advantages of our product compared to 
competing products and the relative safety, efficacy and ease of use of our product; 

the limited size of our sales force and the learning curve required to gain experience selling our product; 

25 

 
 

 

 

the inability to obtain sufficient supply of the components for Senza or secure second-source suppliers if 
our main suppliers are unable to fulfill our orders; 

insufficient financial or other resources to support our commercialization efforts necessary to reach 
profitability; and 

the introduction and market acceptance of new, more effective or less expensive competing products 
and technologies. 

Moreover, physicians and hospitals may not perceive the benefits of our products and may be unwilling to 

change from the SCS devices they are currently using. Communicating the benefits of Senza and HF10 therapy to 
these physicians and hospitals requires a significant commitment by our marketing team and sales organization. 
Physicians and hospitals may be slow to change their practices because of perceived risks arising from the use of 
new products. Physicians may not recommend or use Senza until there is more long-term commercial experience to 
convince them to alter their existing treatment methods, or until they receive additional recommendations from other 
physicians that our product is effective. We cannot predict when, if ever, physicians and hospitals may adopt use of 
our product. If we are unable to educate physicians and hospitals about the advantages of our HF10 therapy and 
Senza, do not continue to gain market acceptance of our product, or fail to significantly grow our market share, we 
will not be able to grow our revenue and our business and financial condition will be adversely affected. 

We are currently, and may in the future become, involved in lawsuits to protect or enforce our intellectual 
property, which could be expensive and time consuming, and ultimately unsuccessful, and could result in the 
diversion of significant resources, thereby hindering our ability to effectively grow sales of our Senza system or 
commercialize future products, if any. If we are unable to obtain, maintain, protect, and enforce our intellectual 
property, our business will be negatively affected. 

The market for medical devices is subject to rapid technological change and frequent litigation regarding 
patent and other intellectual property rights. It is possible that our patents or licenses may not withstand challenges 
made by others or protect our rights adequately. 

Our success depends in large part on our ability to secure effective patent protection for our products and 
processes in the United States and internationally. We have filed and intend to continue to file patent applications for 
various aspects of our technology and trademark applications to protect our brand and business. We seek to obtain 
and maintain patents and other intellectual property rights to restrict the ability of others to market products or 
services that misappropriate our technology and/or infringe our intellectual property to compete with our products. 

However, we face the risks that: 

  We may fail to secure necessary patents, potentially permitting competitors to market competing 

products and make, use or sell products that are substantially the same as ours without incurring the 
sizeable development costs that we have incurred, which would adversely affect our ability to compete. 

 

 

 

Patents may not issue from any of our currently pending or future patent applications. 

Our already-granted patents and any future patents may not survive legal challenges, including the 
pending lawsuit filed by Boston Scientific to their scope, validity or enforceability, or provide 
significant protection for us, and they may be re-examined or invalidated, and/or may be found to be 
unenforceable or not cover competing products. 

Even if our patents are determined by a court to be valid and enforceable, they may not be drafted or 
interpreted broadly enough to prevent others from marketing products and services similar to ours.  
Similarly, others may simply design around our patents. For example, third parties may be able to make 
systems or devices that are similar to ours but that are not covered by the claims of our patents. Third 
parties may assert that we or our licensors were not the first to make the inventions covered by our 
issued patents or pending patent applications. The claims of our issued patents or patent applications 
when issued may not cover our commercial technology or the future products and services that we 
develop. We may not have freedom to operate unimpeded by the patent rights of others. Third parties 
may have dominating, blocking or other patents relevant to our technology of which we are not aware. 

26 

 
In addition, because patent applications in the United States and many foreign jurisdictions are typically 
not published until 18 months after the filing of certain priority documents (or, in some cases, are not 
published until they issue as patents) and because publications in the scientific literature often lag 
behind actual discoveries, we cannot be certain that others have not filed patent applications for our 
technology or our contemplated technology. Any such patent applications may have priority over our 
patent applications or issued patents, which could further require us to obtain rights to issued patents 
covering such technologies. If another party has filed a U.S. patent application on inventions similar to 
ours, depending on when the timing of the filing date falls under certain patent laws, we may have to 
participate in a priority contest (such as an interference proceeding) declared by the U.S. Patent and 
Trademark Office (USPTO), to determine priority of invention in the United States. There may be prior 
public disclosures that could invalidate our inventions or parts of our inventions of which we are not 
aware. Further, we may not develop additional proprietary technologies and, even if we do, they may 
not be patentable. 

 

Patent law can be highly uncertain and involve complex legal and factual questions for which important 
principles remain unresolved. In the United States and in many foreign jurisdictions, policies regarding 
the breadth of claims allowed in patents can be inconsistent. The U.S. Supreme Court and the U.S. 
Court of Appeals for the Federal Circuit have made, and will likely continue to make, changes in how 
the patent laws of the United States are interpreted. Similarly, foreign courts have made, and will likely 
continue to make, changes in how the patent laws in their respective jurisdictions are interpreted. We 
cannot predict future changes in the interpretation of patent laws or changes to patent laws that might be 
enacted into law by U.S. and foreign legislative bodies. Those changes may materially affect our patents 
or patent applications, our ability to obtain patents or the patents and patent applications of our 
licensors. Future protection for our proprietary rights is uncertain because legal means afford only 
limited protection and may not adequately protect our rights or permit us to gain or keep our 
competitive advantage, which could adversely affect our financial condition and results of operations. 

  Monitoring unauthorized uses of our intellectual property is difficult and costly. From time to time, we 

seek to analyze our competitors’ products and services.  For example, in November 2016, we filed a 
complaint against Boston Scientific in order to enforce certain of our patents, and may in the future seek 
to enforce our patents or other proprietary rights against other potential infringements. However, the 
steps we have taken to protect our proprietary rights may not be adequate to prevent misappropriation of 
our intellectual property. We may not be able to detect unauthorized use of, or take appropriate steps to 
enforce, our intellectual property rights. Our competitors may also independently develop similar 
technology. Any inability to meaningfully protect our intellectual property could result in competitors 
offering products that incorporate our product features, which could reduce demand for our products. In 
addition, we may need to defend our patents from third-party challenges, including interferences, 
derivation proceedings, re-examination proceedings, post-grant review, inter partes review, third-party 
submissions, oppositions, nullity actions, or other patent proceedings. We may also need to initiate 
infringement claims or litigation. Adverse proceedings such as litigation or challenges to the validity of 
our patents can be expensive, time consuming and may divert the efforts of our technical and 
managerial personnel, which could in turn harm our business, whether or not we receive a determination 
favorable to us. In addition, in an infringement or other adverse proceeding, a court may decide that the 
patent we seek to enforce is invalid or unenforceable, or may refuse to stop the other party from using 
the technology at issue on the grounds that the patent in question does not cover the technology in 
question. An adverse result in any litigation or proceeding could place one or more of our patents at risk 
of being invalidated, interpreted narrowly or found unenforceable. Some of our competitors may be able 
to devote significantly more resources to intellectual property litigation, and may have significantly 
broader patent portfolios to assert against us, if we assert our rights against them. Further, because of the 
substantial discovery required in connection with intellectual property litigation, there is a risk that some 
of our confidential information could be disclosed or otherwise compromised during litigation. 

27 

 
  We may not be able to accurately estimate or control our future operating expenses in relation to 

obtaining, enforcing and/or defending intellectual property, which could lead to cash shortfalls. Our 
operating expenses may fluctuate significantly in the future as a result of the costs of preparing, filing, 
prosecuting, defending and enforcing patent claims and other patent related costs, including litigation 
costs and the results of such litigation. 

  We may also be forced to enter into cross-license agreements with competitors in order to manufacture, 
use, sell, import and/or export products or services that are covered by our competitors’ intellectual 
property rights. If we need to use our intellectual property to enter such cross-license agreements, it may 
compromise the value of our intellectual property due to the fact that our competitors may be able to 
manufacture, use, sell, import and/or export our patented technology. 

For additional information regarding risks related to our intellectual property, see “Risks Related to 

Intellectual Property.” 

We must continue to educate physicians and demonstrate to them the merits of our HF10 therapy compared to 
those of our competitors. 

Physicians play a significant role in determining the course of a patient’s treatment and the type of product 

that will be used to treat a patient. An important part of our sales process includes the education of physicians on the 
safe and effective use of our HF10 therapy and Senza, particularly because Senza and high-frequency 
neuromodulation treatment is relatively new as compared to existing low-frequency traditional SCS systems.  As a 
result, our success depends, in large part, on effectively marketing our HF10 therapy to physicians, including the 
results of our pivotal SENZA-RCT study. In order for us to sell Senza, we must successfully demonstrate to 
physicians the merits of our HF10 therapy compared to our competitors’ SCS systems for use in treating patients 
with chronic leg and back pain. Acceptance of our HF10 therapy depends on educating physicians as to the 
distinctive characteristics, perceived benefits, safety, ease of use and cost-effectiveness of Senza as compared to our 
competitors’ SCS systems, and communicating to physicians the proper application of our HF10 therapy. Physicians 
typically need to perform several procedures to become comfortable using HF10 therapy and Senza. If a physician 
experiences difficulties during an initial procedure or otherwise, that physician may be less likely to continue to use 
our product or to recommend it to other physicians. It is critical to the success of our commercialization efforts that 
we educate physicians on the proper use of Senza. If we are not successful in educating physicians and convincing 
them of the merits of our HF10 therapy or educating them on the use of Senza, they may not use Senza and we may 
be unable to increase our sales, sustain our growth or achieve profitability. 

In addition, we believe support of our products by physicians is essential for market acceptance and adoption. 

If we do not receive support from physicians or long-term data does not show the benefits of using our HF10 
therapy, physicians may not use Senza. In such circumstances, our results of operations would be materially 
adversely affected. It is also important for our growth that these physicians advocate for the benefits of our products 
in the broader marketplace. If physicians misuse or ineffectively use our products, it could result in unsatisfactory 
patient outcomes, patient injuries, negative publicity or lawsuits against us, any of which could have an adverse 
effect on our business. 

Our competitors are large, well-established companies with substantially greater resources than we have and 
have a long history of competing in the SCS market. 

Our current and potential competitors are publicly traded, or are divisions of publicly traded, major medical 
device companies that have substantially greater financial, technical, sales and marketing resources than we have. 
We estimate the existing global SCS market to be approximately $1.6 to $1.8 billion, with the United States 
comprising approximately 80% of the market. Given the size of the existing and potential market in the United 
States, we expect that as we work to increase our market position and penetration in the United States our 
competitors will take aggressive action to protect their current market position.  For example, in May 2015, a unit of 
Boston Scientific, one of our principal competitors, filed with the USPTO two petitions for inter partes review 
challenging the validity of our U.S. Patent No. 8,359,102 (the ‘102 patent), which the Patent Trial and Appeals 
Board (PTAB) at the USPTO denied in November 2015, and, in December 2016, filed another lawsuit against us in 
the U.S. District Court for the District of Delaware alleging that we infringed their patents covering technology 

28 

 
related to stimulation leads, batteries and telemetry units.  We will face significant competition in establishing our 
market share in the United States and may encounter unforeseen obstacles and competitive challenges in the United 
States. 

In addition, we face a particular challenge overcoming the long-standing practices by some physicians of 

using the neuromodulation products of our larger, more established competitors. Physicians who have completed 
many successful implants using the neuromodulation products made by these competitors may be reluctant to try 
new products from a source with which they are less familiar. If these physicians do not try and subsequently adopt 
our product, then our revenue growth will slow or decline. 

Further, a number of our competitors are currently conducting, or we anticipate will be conducting, clinical 

trials to demonstrate the results of their SCS systems. The results of these trials may be equivalent to, or potentially 
better than, the results of our pivotal U.S. trial. 

If our competitors are better able to develop and market neuromodulation products that are safer, more effective, 
less costly, easier to use or otherwise more attractive than Senza, our business will be adversely impacted. 

The medical device industry is highly competitive and subject to technological change. Our success depends, 
in part, upon our ability to establish a competitive position in the neuromodulation market by securing broad market 
acceptance of our HF10 therapy and Senza for the treatment of chronic pain conditions. Any product we develop 
that achieves regulatory clearance or approval, including Senza, will have to compete for market acceptance and 
market share. We believe that the primary competitive factors in the neuromodulation market are demonstrated 
clinical effectiveness, product safety, reliability and durability, ease of use, product support and service, minimal 
side effects and salesforce experience and relationships. We face significant competition in the United States and 
internationally, which we believe will continue to intensify as we grow our presence in the U.S. market. For 
example, our major competitors, Medtronic, Boston Scientific and Abbott Laboratories, which recently acquired 
St. Jude Medical, each has approved neuromodulation systems in at least the United States, Europe, and Australia 
and have been established for several years.  In addition, in October 2016, St. Jude Medical (now a part of Abbott 
Laboratories) obtained FDA approval for a SCS system that offers an alternate low frequency waveform called 
BurstDR, and in February 2016, the company gained approval for a neuromodulation system that stimulates the 
dorsal root ganglion for treatment of focal pain and complex regional pain syndrome.  Additionally, we believe that 
Boston Scientific is in the later stages of a randomized clinical trial of high-frequency SCS therapy.  In addition to 
these major competitors, we may also face competition from smaller companies such as Nuvectra, Saluda and 
Stimwave.  Additionally, there are other emerging competitors with active neuromodulation system development 
programs that may emerge in the future. Many of the companies developing or marketing competing products enjoy 
several advantages over us, including: 

 

 

 

 

 

 

 

 

 

 

more experienced sales forces; 

greater name recognition; 

more established sales and marketing programs and distribution networks; 

earlier regulatory approval; 

long established relationships with physicians and hospitals; 

significant patent portfolios, including issued U.S. and foreign patents and pending patent applications, 
as well as the resources to enforce patents against us or any of our third-party suppliers and distributors; 

the ability to acquire and integrate our competitors and/or their technology; 

demonstrated ability to develop product enhancements and new product offerings; 

established history of product reliability, safety and durability; 

the ability to offer rebates or bundle multiple product offerings to offer greater discounts or incentives; 

29 

 
 

 

greater financial and human resources for product development, sales, and marketing; and 

greater experience in and resources for conducting R&D, clinical studies, manufacturing, preparing 
regulatory submissions, obtaining regulatory clearance or approval for products and marketing approved 
products. 

Our competitors may develop and patent processes or products earlier than we do, obtain patents that may 
apply to us at any time, obtain regulatory clearance or approvals for competing products more rapidly than we do or 
develop more effective or less expensive products or technologies that render our technology or products obsolete or 
less competitive. We also face fierce competition in recruiting and retaining qualified sales, scientific, and 
management personnel, establishing clinical trial sites and enrolling patients in clinical studies. If our competitors 
are more successful than we are in these matters, our business may be harmed. 

Our success depends on physicians’ use of our HF10 therapy to treat chronic back pain. 

Our success is dependent on physicians’ acceptance and use of our HF10 therapy to treat chronic back pain. 
We believe a significant limitation of current neuromodulation systems is the limited evidence supporting efficacy 
of traditional SCS for treating chronic back pain. Senza utilizes high-frequency stimulation technology capable of 
delivering waveform of up to 10,000 Hz for spinal cord stimulation that has been shown to be effective in the 
treatment of both leg and back pain. However, we may face challenges convincing physicians, many of whom have 
extensive experience with competitors’ SCS products and established relationships with other companies, to 
appreciate the benefits of HF10 therapy and, in particular, its ability to treat back pain as well as leg pain, and adopt 
it for treatment of their patients. If Senza is unable to gain acceptance by physicians for the treatment of back pain, 
our potential to expand the existing neuromodulation market will be significantly limited and our revenue potential 
will be negatively impacted. 

If third-party payors do not provide adequate coverage and reimbursement for the use of Senza, our revenue will 
be negatively impacted. 

Our success in marketing Senza depends and will depend in large part on whether U.S. and international 
government health administrative authorities, private health insurers and other organizations adequately cover and 
reimburse customers for the cost of our products. 

In the United States, we expect to derive nearly all our sales from sales of Senza to hospitals and outpatient 
surgery centers who typically bill various third-party payors, including Medicare, Medicaid, private commercial 
insurance companies, health maintenance organizations and other healthcare-related organizations, to cover all or a 
portion of the costs and fees associated with Senza and bill patients for any applicable deductibles or co-payments. 
Access to adequate coverage and reimbursement for SCS procedures using Senza (and our other products in 
development) by third-party payors is essential to the acceptance of our products by our customers. 

We believe that SCS procedures using Senza are adequately described by existing CPT, HCPCS II and ICD-

10-CM codes for the implantation of spinal cord stimulators and related leads performed in various sites of care, 
although such codes generally do not specifically describe procedures using either low-frequency or high-frequency 
stimulation. In the United States, CMS has approved a transitional pass-through payment for High-Frequency 
Stimulation under the Medicare hospital outpatient prospective payment system effective as of January 1, 
2016.  This pass-through payment for HF10 therapy is in addition to the established reimbursement for spinal cord 
stimulation devices; however, this pass-through payment is scheduled to expire on December 31, 2017.   

We believe that some of our target customers may be unwilling to adopt Senza over more established or 
lower-cost therapeutic alternatives already available or subsequently become available. Further, any decline in the 
amount payors are willing to reimburse our customers for SCS procedures using Senza could make it difficult for 
new customers to adopt Senza and could create additional pricing pressure for us, which could adversely affect our 
ability to invest in and grow our business. 

Third-party payors, whether foreign or domestic, or governmental or commercial, are developing increasingly 

sophisticated methods of controlling healthcare costs. In addition, in the United States, no uniform policy of 

30 

 
coverage and reimbursement for medical device products and services exists among third-party payors. Therefore, 
coverage and reimbursement for medical device products and services can differ significantly from payor to payor. 
For example, certain regional Blue Cross Blue Shield plans have denied coverage for Senza on the basis that high-
frequency neuromodulation is investigational and/or experimental. We continue to engage in efforts to convince 
such payors of the advantages of HF10 therapy, and while we have overturned some investigational/experimental 
designations, such as Blue Cross Blue Shield Highmark and Blue Cross Blue Shield of Alabama, there can be no 
assurances that we are successful in overturning negative coverage decisions by private health insurance plans. In 
addition, payors continually review new technologies for possible coverage and can, without notice, deny coverage 
for these new products and procedures. As a result, the coverage determination process is often a time-consuming 
and costly process that will require us to provide scientific and clinical support for the use of our products to each 
payor separately, with no assurance that coverage and adequate reimbursement will be obtained, or maintained if 
obtained. 

Reimbursement systems in international markets vary significantly by country and by region within some 
countries, and reimbursement approvals must be obtained on a country-by-country basis. In many international 
markets, a product must be approved for reimbursement before it can be approved for sale in that country. Further, 
many international markets have government-managed healthcare systems that control reimbursement for new 
devices and procedures. For example, the governmental healthcare system in France has not yet approved 
reimbursement of Senza. In most markets there are private insurance systems as well as government-managed 
systems. If sufficient coverage and reimbursement is not available for our current or future products, in either the 
United States or internationally, the demand for our products and our revenues will be adversely affected. 

If we fail to develop and retain an effective direct sales force in the United States, our business could suffer. 

As we continue our commercial launch and increase our marketing efforts, we will need to retain, develop and 
grow the number of direct sales personnel that we employ. We intend to continue to make a significant investment in 
recruiting and training sales representatives and clinical representatives as we continue our commercial launch in the 
United States. There is significant competition for sales personnel experienced in relevant medical device sales. Once 
hired, the training process is lengthy because it requires significant education for new sales representatives to achieve 
the level of clinical competency with our products expected by physicians. Upon completion of the training, our sales 
representatives typically require lead time in the field to grow their network of accounts and achieve the productivity 
levels we expect them to reach in any individual territory. Furthermore, the use of our products often requires or 
benefits from direct support from us. If we are unable to attract, motivate, develop and retain a sufficient number of 
qualified sales personnel, or if our sales representatives do not achieve the productivity levels we expect them to reach, 
our revenue will not grow at the rate we expect and our financial performance will suffer. Also, to the extent we hire 
personnel from our competitors, our new sales representatives will usually be subject to restrictive covenants with their 
former employers, including non-competition, non-solicitation and/or confidentiality provisions.  As a result, we may 
have to wait until applicable non-competition provisions have expired before deploying such personnel in restricted 
territories or incur costs to relocate personnel outside of such territories. We and certain of our new sales 
representatives have been, continue to be, and may in the future be, subject to allegations that these new hires have 
violated the non-competition clauses, been improperly solicited or divulged to us proprietary or other confidential 
information of their former employers. Any of these risks may adversely affect our business. 

Our past results in the international markets in which we commercialize Senza should not be relied upon as an 
indication of our future performance in those markets or in the United States. 

Our revenue from international markets has increased from $18.2 million for the year ended December 31, 

2012 to $55.2 million for the year ended December 31, 2016 on the basis of our sales of Senza in Europe and 
Australia; however, we do not expect to continue this rate of revenue growth in these international markets. Due to 
our current penetration in these markets, we expect our revenue to stay stable in these international markets and not 
grow at rate it did historically. Furthermore, given our recent commercialization in the United States, we have not 
developed an extended history of payment and therefore we may encounter difficulties in collecting receivables 
related to our U.S. sales. 

In addition, the characteristics of these markets differ significantly from the U.S. market, including as a result 

of differences in payor systems, competitive dynamics, market size and patient treatment regimens. As a result of 

31 

 
the differences in these markets, you should not compare our financial results in the international market to any 
potential future results in the U.S. market nor should you rely on our past results as an indication of our future 
performance. 

If we fail to maintain U.S. Food and Drug Administration approval to market and sell Senza, or if such approval 
is impacted in the future, we will be unable to commercially distribute and market Senza in the United States. 
Further, we may not be able to obtain required regulatory approvals to expand the indications for which we may 
market and sell Senza. 

The FDA requires manufacturers of medical devices to maintain regulatory approval by filing timely reports 
and complying with numerous regulations.  While we have received FDA approval of our Senza PMA application, 
there can be no assurance that approval will be maintained. For example: 

 

 

 

we may not be able to maintain to the FDA’s satisfaction that our product is safe and effective for its 
intended use; 

we may fail to comply with the guidelines required by FDA and other agencies to maintain our PMA 
approval; and 

the manufacturing processes and facilities we and our vendors use may not meet applicable 
requirements to maintain our PMA approval. 

In addition, we may suffer from product liability or other issues that impact our ability to continue to market 

the Senza system in the United States. 

Failing to maintain FDA approval could result in unexpected and significant costs for us and consume 
management’s time and other resources. The FDA could ask us to improve or augment manufacturing processes, 
collect and provide data on the quality or safety of our product or issue us warning letters relating to matters that 
may result in removal of our product from the market. Additionally, we will be required to obtain FDA approval 
prior to making any modification to the device, and the FDA may revoke the approval or impose other restrictions if 
post-market data demonstrates safety issues or lack of effectiveness. If we are unable to obtain and maintain the 
necessary regulatory approvals, our financial condition may be adversely affected, and our ability to grow 
domestically and internationally would likely be limited. 

We are currently conducting clinical trials for Senza to explore the potential for HF10 therapy to treat other 

chronic pain indications, including chronic upper limb and neck pain, painful neuropathies and non-surgical 
refractory back pain. We will likely need to conduct additional clinical studies in the future to support approval for 
these new indications. Senza may not be approved for these additional indications. 

Traditional SCS has been available for almost 50 years, while Senza has only been commercially available since 
2010 and, as a result, we have a limited track record compared to our competitors. 

Traditional SCS has been commercialized since 1967, while we only began commercializing Senza 

internationally in 2010 and in the United States since May 2015. Because we have a limited commercial track record 
compared to our competitors and Senza has been implanted in patients for significantly less time than our 
competitors’ products, physicians may be slower to adopt or recommend Senza. Further, while we believe our 
international commercial experience and recent U.S. commercial experience, and our European two-year study and 
U.S. pivotal study support the safety and effectiveness of our HF10 therapy, future studies or patient experience over 
a longer period of time may indicate that treatment with our HF10 therapy does not achieve non-inferiority status as 
compared to treatment with competitive products or that our HF10 therapy causes unexpected or serious 
complications or other unforeseen negative effects. Such results would likely slow the adoption of Senza and 
significantly reduce our sales, which would harm our business and adversely affect our results of operations. 

Furthermore, if patients with traditional SCS implantations were to experience unexpected or serious 
complications or other unforeseen effects, the market for Senza may be adversely affected, even if such effects are 
not applicable to Senza. 

32 

 
Our international operations subject us to certain operating risks, which could adversely impact our results of 
operations and financial condition. 

In 2010, we began selling Senza in Europe and, in August 2011, we began selling Senza in Australia. As of 
December 31, 2016, we sell Senza directly in Austria, Switzerland, United Kingdom, Sweden, Australia, Belgium, 
Luxembourg, Norway and Germany and through distributors and agents located in the Netherlands, Spain, Italy, 
Slovakia, Turkey, Kuwait and Ireland. The sale and shipment of Senza across international borders, as well as the 
purchase of components from international sources, subject us to United States and foreign governmental trade, 
import and export and customs regulations and laws. 

Compliance with these regulations and laws is costly and exposes us to penalties for non-compliance. Other 
laws and regulations that can significantly impact us include various anti-bribery laws, including the U.S. Foreign 
Corrupt Practices Act, as well as export controls laws. Any failure to comply with applicable legal and regulatory 
obligations could impact us in a variety of ways that include, but are not limited to, significant criminal, civil and 
administrative penalties, including imprisonment of individuals, fines and penalties, denial of export privileges, 
seizure of shipments, restrictions on certain business activities and exclusion or debarment from government 
contracting. 

Our international operations expose us and our distributors to risks inherent in operating in foreign 

jurisdictions. These risks include: 

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difficulties in enforcing our intellectual property rights and in defending against third-party threats and 
intellectual property enforcement actions against us, our distributors, or any of our third-party suppliers; 

reduced or varied protection for intellectual property rights in some countries; 

pricing pressure that we may experience internationally; 

foreign currency exchange rate fluctuations; 

a shortage of high-quality sales people and distributors; 

third-party reimbursement policies that may require some of the patients who receive our products to 
directly absorb medical costs or that may necessitate the reduction of the selling prices of Senza; 

relative disadvantages compared to competitors with established business and customer relationships; 

the imposition of additional U.S. and foreign governmental controls or regulations; 

economic instability; 

changes in duties and tariffs, license obligations and other non-tariff barriers to international trade; 

the imposition of restrictions on the activities of foreign agents, representatives and distributors; 

scrutiny of foreign tax authorities that could result in significant fines, penalties and additional taxes 
being imposed on us; 

laws and business practices favoring local companies; 

longer payment cycles; 

difficulties in maintaining consistency with our internal guidelines; 

difficulties in enforcing agreements and collecting receivables through certain foreign legal systems; 

the imposition of costly and lengthy new export licensing requirements; 

the imposition of U.S. or international sanctions against a country, company, person or entity with 
whom we do business that would restrict or prohibit continued business with the sanctioned country, 
company, person or entity; and 

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the imposition of new trade restrictions. 

33 

 
If we experience any of these risks, our sales in non-U.S. jurisdictions may be harmed and our results of 

operations would suffer. 

Changes in tax law and other developments resulting from the new presidential administration in the United 
States may have a material adverse effect on our business, financial condition and results of operations. 

Changes in laws and policy relating to taxes or trade may have an adverse effect on our business, financial 

condition and results of operations.  Potential tax reforms in the United States may result in significant changes to 
current U.S. tax rules and regulations. These potential changes may trigger an adverse effect on our business, 
financial conditions and results of operations.  

Although we are unable to predict what, if any, changes in tax law will occur, the 2016 U.S. presidential 
election introduced a great deal of uncertainty regarding current tax and trade policies, tariffs and government 
regulations, which if altered could have the potential to create a significant adverse effect on trade between the U.S. 
and other countries. Overall, changes in international trade relations and changes to U.S. tax or other laws (including 
new or changes in regulations promulgated by the U.S. Internal Revenue Service and the U.S. Department of the 
Treasury), such as the imposition of or increase in tariffs or other trade barriers, could materially and adversely 
impact our effective tax rate, increase our costs and reduce the competitiveness of our products. 

We are dependent upon third-party manufacturers and suppliers, in some cases sole- or single-source suppliers, 
making us vulnerable to supply shortages and problems and price fluctuations, which could harm our business. 

We rely on a limited number of suppliers who manufacture and assemble certain components of Senza. 

Our suppliers may encounter problems during manufacturing for a variety of reasons, including, for example, 

failure to follow specific protocols and procedures, failure to comply with applicable legal and regulatory 
requirements, equipment malfunction and environmental factors, failure to properly conduct their own business 
affairs and infringement of third-party intellectual property rights, any of which could delay or impede their ability 
to meet our requirements. Our reliance on these third-party suppliers also subjects us to other risks that could harm 
our business, including: 

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third parties may threaten or enforce their intellectual property rights against our suppliers, which may 
cause disruptions or delays in shipment, or may force our suppliers to cease conducting business with 
us; 

we may not be able to obtain adequate supplies from one or more vendors in a timely manner or on 
commercially reasonable terms; 

we are not a major customer of many of our suppliers, and these suppliers may therefore give other 
customers’ needs higher priority than ours; 

our suppliers, especially new suppliers, may make errors in manufacturing that could negatively affect 
the efficacy or safety of Senza, impacting our ability to maintain our PMA approval, or cause delays in 
shipment, impacting our ability to meet demand in the United States or international markets; 

we may have difficulty locating and qualifying alternative suppliers; 

switching components or suppliers may require product redesign and possibly submission to FDA, EEA 
Notified Bodies or other foreign regulatory bodies, which could significantly impede or delay our 
commercial activities; 

one or more of our sole- or single-source suppliers may be unwilling or unable to supply components of 
Senza, or may supply products that do not meet our product requirements; 

other customers may use fair or unfair negotiation tactics and/or pressures to impede our use of the 
supplier; 

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 

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the occurrence of a fire, natural disaster or other catastrophe impacting one or more of our suppliers may 
affect their ability to deliver products to us in a timely manner; and 

our suppliers may encounter financial or other business hardships unrelated to our demand, which could 
inhibit their ability to fulfill our orders and meet our requirements. 

We may not be able to quickly establish additional or alternative suppliers for commercialization in the United 

States if necessary, in part because we may need to undertake additional activities to qualify such suppliers as 
required by the regulatory approval process. Any interruption or delay in obtaining products from our third-party 
suppliers, or our inability to obtain products from qualified alternate sources at acceptable prices in a timely manner, 
could impair our ability to meet the demand of our customers and cause them to switch to competing products. 
Given our reliance on certain single-source suppliers, we are especially susceptible to supply shortages because we 
do not have alternate suppliers currently available. 

We rely upon third-party, single-source, and in certain cases sole-source, suppliers for many of the components 
and materials used in Senza, and for critical manufacturing and packaging services, and the loss of any of these 
suppliers could harm our business. 

A number of the critical components used in Senza are supplied to us from single-source, or in certain cases 

sole-source, suppliers, including leads, lead extenders, surgical leads, neurostimulator components and telemetry 
modules. Our ability to supply Senza commercially depends, in part, on our ability to obtain a supply of these 
components that has been manufactured in accordance with regulatory requirements and in sufficient quantities for 
commercialization and clinical testing. We have not entered into manufacturing, supply or quality agreements with 
some of our single-source and sole-source suppliers, some of which supply components critical to our products. We 
are not certain that our single-source or sole-source suppliers will be able to meet our demand for their products and 
services, either because of the nature of our agreements with those suppliers, or our limited experience with those 
suppliers, or due to our relative importance as a customer to those suppliers or otherwise. It may be difficult for us to 
assess their ability to timely meet our demand in the future based on past performance. While our suppliers have 
generally met our demand for their products on a timely basis in the past, they may subordinate our needs in the 
future to the needs of their other customers. 

Establishing additional or replacement suppliers for the components or processes used in Senza, if required, 
may not be accomplished quickly. If we are able to find a replacement supplier, such replacement supplier would 
need to be qualified and may require additional regulatory authority approval, which could result in further delay. 
While we seek to maintain adequate inventory of the single-source or sole-source components and materials used in 
our products, any interruption or delay in the supply of components or materials, or our inability to obtain 
components or materials from alternate sources at acceptable prices in a timely manner, could impair our ability to 
meet the demand of our customers and cause them to cancel orders.  In addition, from time to time, certain of our 
suppliers experience interruptions and variances in their manufacturing processes, including suppliers of our leads 
and batteries.  Because we are reliant on these single source suppliers, we are particularly susceptible to supply 
shortages and, if one of our suppliers were to experience an ongoing or continued manufacturing problem, and, in 
particular, our leads and battery suppliers, our ability to meet our forecasted commercial demand could be materially 
and negatively impacted. 

If our third-party suppliers fail to deliver the required commercial quantities of materials, or the level of 
services we require, on a timely basis and at commercially reasonable prices, and we are unable to find one or more 
replacement suppliers capable of production at a substantially equivalent cost in substantially equivalent volumes 
and quality, and on a timely basis, the continued commercialization of Senza would be impeded, delayed, limited or 
prevented, which could harm our business, results of operations, financial condition and prospects. 

We may not be able to establish or strengthen our brand. 

We believe that establishing and strengthening the Nevro and Senza brands is critical to achieving widespread 

acceptance of HF10 therapy, particularly because of the highly competitive nature of the market for SCS products. 
Promoting and positioning our brand will depend largely on the success of our marketing efforts and our ability to 
provide physicians with a reliable product for successful treatment of chronic leg and back pain. Additionally, we 

35 

 
believe the quality and reliability of our product is critical to building physician support of this new therapy in the 
United States and any negative publicity regarding the quality or reliability of Senza could significantly damage our 
reputation in the market. Further, given the established nature of our competitors, and our recent commercial launch 
in the United States, it is likely that our future marketing efforts will require us to incur significant additional 
expenses. These brand promotion activities may not yield increased sales and, even if they do, any sales increases 
may not offset the expenses we incur to promote our brand. If we fail to successfully promote and maintain our 
brand, or if we incur substantial expenses in an unsuccessful attempt to promote and maintain our brand, our HF10 
therapy may not be accepted by physicians, which would adversely affect our business, results of operations and 
financial condition. 

Our ability to achieve profitability will depend, in part, on our ability to reduce the per unit manufacturing cost of 
Senza. 

Currently, the gross profit generated from the sale of Senza is not sufficient to cover our operating expenses. 

To achieve our operating and strategic goals, we will, among other things, need to reduce the per-unit manufacturing 
cost of Senza. This cannot be achieved without increasing the volume of components that we purchase in order to 
take advantage of volume-based pricing discounts, improving manufacturing efficiency or increasing our volume to 
leverage manufacturing overhead costs. If we are unable to improve manufacturing efficiency and reduce 
manufacturing overhead costs per unit, our ability to achieve profitability will be severely constrained. Any increase 
in manufacturing volumes is dependent upon a corresponding increase in sales. The occurrence of one or more 
factors that negatively impact the manufacturing or sales of Senza or reduce our manufacturing efficiency may 
prevent us from achieving our desired reduction in manufacturing costs, which would negatively affect our 
operating results and may prevent us from attaining profitability. 

If we fail to properly manage our anticipated growth, our business could suffer. 

We have been growing rapidly in recent periods and have a relatively short history of operating as a 

commercial company. As an organization, we have only recently commercially launched our product in the United 
States and commenced a sales representative training program. A commercial launch and training program of this 
size is a significant undertaking that requires substantial financial and managerial resources. We intend to continue 
to grow and may experience periods of rapid growth and expansion, which could place a significant additional strain 
on our limited personnel, information technology systems and other resources. In particular, the hiring of our direct 
sales force in the United States requires significant management, financial and other supporting resources. Any 
failure by us to manage our growth effectively could have an adverse effect on our ability to achieve our 
development and commercialization goals. 

To achieve our revenue goals, we must successfully increase manufacturing output to meet expected customer 
demand. In the future, we may experience difficulties with manufacturing yields, quality control, component supply 
and shortages of qualified personnel, among other problems. These problems could result in delays in product 
availability and increases in expenses. Any such delay or increased expense could adversely affect our ability to 
generate revenue. 

Future growth will also impose significant added responsibilities on management, including the need to 
identify, recruit, train and integrate additional employees. In addition, rapid and significant growth will place a strain 
on our administrative and operational infrastructure. 

In order to manage our operations and growth we will need to continue to improve our operational and 
management controls, reporting and information technology systems and financial internal control procedures. If we 
are unable to manage our growth effectively, it may be difficult for us to execute our business strategy and our 
operating results and business could suffer. 

If we fail to receive access to hospital facilities, our sales may decrease. 

In the United States, in order for physicians to use Senza, the hospital facilities where these physicians treat 

patients typically require us to enter into purchasing contracts. The process of securing a satisfactory contract can be 

36 

 
lengthy and time-consuming and require extensive negotiations and management time. In the EU, from time to time, 
certain institutions require us to engage in a contract bidding process in the event that such institutions are 
considering making purchase commitments that exceed specified cost thresholds, which vary by jurisdiction. These 
processes are only open at certain periods of time, and we may not be successful in the bidding process. If we do not 
receive access to hospital facilities via these contracting processes or otherwise, or if we are unable to secure 
contracts or tender successful bids, our sales may stagnate or decrease and our operating results may be harmed. 
Furthermore, we may expend significant effort in these time-consuming processes and still may not obtain a 
purchase contract from such hospitals. 

We rely in part on a small group of third-party distributors to effectively distribute our products in outside the 
United States. 

We depend in part on medical device distributors for the marketing and sales of our products in certain 
territories in Europe. We depend on these distributors’ efforts to market our products, yet we are unable to control 
their efforts completely. These distributors typically sell a variety of other, non-competing products that may limit 
the resources they dedicate to selling Senza. In addition, we are unable to ensure that our distributors comply with 
all applicable laws regarding the sale of our products. If our distributors fail to effectively market and sell Senza in 
full compliance with applicable laws, our operating results and business may suffer. Recruiting and retaining 
qualified third-party distributors and training them in our technology and product offering requires significant time 
and resources. To develop and expand our distribution, we must continue to scale and improve our processes and 
procedures that support our distributors. Further, if our relationship with a successful distributor terminates, we may 
be unable to replace that distributor without disruption to our business. If we fail to maintain positive relationships 
with our distributors, fail to develop new relationships with other distributors, including in new markets, fail to 
manage, train or incentivize existing distributors effectively, or fail to provide distributors with competitive products 
on attractive terms, or if these distributors are not successful in their sales efforts, our revenue may decrease and our 
operating results, reputation and business may be harmed. 

We may face product liability claims that could result in costly litigation and significant liabilities. 

Manufacturing and marketing Senza, and clinical testing of our HF10 therapy, may expose us to product 
liability and other tort claims. Although we have, and intend to maintain, liability insurance, the coverage limits of 
our insurance policies may not be adequate and one or more successful claims brought against us may have a 
material adverse effect on our business and results of operations. For example, the U.S. Supreme Court recently 
declined to hear an appeal where the U.S. Court of Appeals for the Ninth Circuit ruled that the Medical Device 
Amendments of 1976 to the FFDCA did not preempt state laws in a product liability case involving a medical device 
company. If other courts in the United States adopt similar rulings, we may be subject to increased litigation risk in 
connection with our products. Product liability claims could negatively affect our reputation, continued product 
sales, and our ability to obtain and maintain regulatory approval for our products. 

If clinical studies for future indications do not produce results necessary to support regulatory clearance or 
approval in the United States or elsewhere, we will be unable to commercialize Senza for these indications. 

We are currently conducting clinical trials for Senza to explore the potential for HF10 therapy to treat other 

chronic pain indications, including chronic upper limb and neck pain, painful neuropathies and non-surgical 
refractory back pain. We will likely need to conduct additional clinical studies in the future to support regulatory 
approval for the use of Senza to treat these new indications. Clinical testing can take many years, is expensive and 
carries uncertain outcomes. The initiation and completion of any of these studies may be prevented, delayed, or 
halted for numerous reasons, including, but not limited to, the following: 

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the FDA, IRBs, Ethics Committees, EU Competent Authorities or other regulatory authorities do not 
approve a clinical study protocol, force us to modify a previously approved protocol, or place a clinical 
study on hold; 

patients do not enroll in, or enroll at a lower rate than we expect, or do not complete a clinical study; 

patients or investigators do not comply with study protocols; 

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patients do not return for post-treatment follow-up at the expected rate; 

patients experience serious or unexpected adverse side effects for a variety of reasons that may or may 
not be related to our products such as the advanced stage of co-morbidities that may exist at the time of 
treatment, causing a clinical study to be put on hold; 

sites participating in an ongoing clinical study withdraw, requiring us to engage new sites; 

difficulties or delays associated with establishing additional clinical sites; 

third-party clinical investigators decline to participate in our clinical studies, do not perform the clinical 
studies on the anticipated schedule, or perform in a manner inconsistent with the investigator agreement, 
clinical study protocol, good clinical practices, other FDA, IRB or Ethics Committee requirements, and 
EEA Member State or other foreign regulations governing clinical trials; 

third-party organizations do not perform data collection and analysis in a timely or accurate manner; 

regulatory inspections of our clinical studies or manufacturing facilities require us to undertake 
corrective action or suspend or terminate our clinical studies; 

changes in federal, state, or foreign governmental statutes, regulations or policies; 

interim results are inconclusive or unfavorable as to immediate and long-term safety or efficacy; 

the study design is inadequate to demonstrate safety and efficacy; or 

the statistical endpoints are not met. 

Clinical failure can occur at any stage of the testing. Our clinical studies may produce negative or inconclusive 

results, and we may decide, or regulators may require us, to conduct additional clinical or non-clinical studies in 
addition to those we have planned. Our failure to adequately demonstrate the safety and effectiveness of any of our 
devices would prevent receipt of regulatory clearance or approval and, ultimately, the commercialization of that 
device or indication for use. 

We could also encounter delays if the FDA concludes that our financial relationships with investigators results 

in a perceived or actual conflict of interest that may have affected the interpretation of a study, the integrity of the 
data generated at the applicable clinical trial site or the utility of the clinical trial itself. Principal investigators for 
our clinical trials may serve as scientific advisors or consultants to us from time to time and receive cash 
compensation and/or equity-based awards in connection with such services. If these relationships and any related 
compensation to or ownership interest by the clinical investigator carrying out the study result in perceived or actual 
conflicts of interest, or if the FDA concludes that the financial relationship may have affected interpretation of the 
study, the integrity of the data generated at the applicable clinical trial site may be questioned and the utility of the 
clinical trial itself may be jeopardized, which could result in the FDA refusing to accept the data as support for our 
future applications. Any such delay or rejection could prevent us from commercializing any of our products 
currently in development. 

Even if our products are approved in the United States, Australia and the EEA, comparable regulatory 
authorities of additional foreign countries must also approve the manufacturing and marketing of our products in 
those countries. Approval procedures vary among jurisdictions and can involve requirements and administrative 
review periods different from, and greater than, those in the United States, Australia or the EEA, including 
additional preclinical studies or clinical trials. Any of these occurrences may harm our business, financial condition 
and prospects significantly. 

If we fail to retain our key executives or recruit and hire new employees, our operations and financial results may 
be adversely effected while we attract other highly qualified personnel. 

Our future success depends, in part, on our ability to continue to retain our executive officers and other key 

employees, and recruit and hire new employees. All of our executive officers and other employees are at-will 
employees, and therefore may terminate employment with us at any time with no advance notice. The replacement 

38 

 
of any of our key personnel likely would involve significant time and costs, may significantly delay or prevent the 
achievement of our business objectives and may harm our business. 

In addition, many of our employees have become, or will soon become, vested in a substantial amount of 

Company stock or be able to exercise a substantial number of stock options. Our employees may be more likely to 
leave us if the shares they own or the shares underlying their vested options have significantly appreciated in value 
relative to the original purchase prices of the shares or the exercise prices of the options, or if the exercise prices of 
the options that they hold are significantly below the market price of our common stock. Further, our employees’ 
ability to exercise those options and sell their stock in a public market may result in a higher than normal turnover 
rate. 

Our future success also depends on our ability to retain executive officers and other key employees and attract 

new key employees. Many executive officers and other employees in the neuromodulation and medical device 
industry are subject to strict non-competition, non-solicitation and/or confidentiality agreements with their 
employers, including our main competitors Medtronic plc, Boston Scientific and Abbott Laboratories (which 
recently acquired St. Jude Medical). Our competitors may allege breaches of, and seek to enforce, such non-
competition, non-solicitation and/or confidentiality agreements or initiate litigation based on such agreements, 
particularly now that we have entered the U.S. market. Such litigation, whether or not meritorious, may impede our 
ability to attract, hire or utilize executive officers and other key employees who have been or are currently employed 
by our competitors. 

Failure to protect our information technology infrastructure against cyber-based attacks, network security 
breaches, service interruptions, or data corruption could significantly disrupt our operations and adversely affect 
our business and operating results. 

We rely on information technology and telephone networks and systems, including the Internet, to process and 

transmit sensitive electronic information and to manage or support a variety of business processes and activities, 
including sales, billing, marketing, procurement and supply chain, manufacturing and distribution. We use enterprise 
information technology systems to record, process and summarize financial information and results of operations for 
internal reporting purposes and to comply with regulatory, financial reporting, legal and tax requirements. Our 
information technology systems, some of which are managed by third-parties, may be susceptible to damage, 
disruptions or shutdowns due to computer viruses, attacks by computer hackers, failures during the process of 
upgrading or replacing software, databases or components thereof, power outages, hardware failures, 
telecommunication failures, user errors or catastrophic events. Despite the precautionary measures we have taken to 
prevent breakdowns in our information technology and telephone systems, if our systems suffer severe damage, 
disruption or shutdown and we are unable to effectively resolve the issues in a timely manner, our business and 
operating results may suffer. 

Risks Related to Intellectual Property 

We currently are, and may in the future become, involved in lawsuits to defend ourselves against intellectual 
property disputes, which could be expensive and time consuming, and ultimately unsuccessful, and could result 
in the diversion of significant resources, and hinder our ability to commercialize our existing or future products. 

Our success depends in part on not infringing the patents or violating the other proprietary rights of others. 
Intellectual property disputes can be costly to defend and may cause our business, operating results and financial 
condition to suffer. Significant litigation regarding patent rights occurs in the medical industry. Whether merited or 
not, it is possible that U.S. and foreign patents and pending patent applications controlled by third parties may be 
alleged to cover our products. For example, on December 9, 2016, Boston Scientific filed a patent infringement 
lawsuit alleging our manufacture, use and sale of the Senza system infringes certain of Boston Scientific’s patents 
covering technology related to stimulation leads, batteries and telemetry units. We may also face allegations that our 
employees have misappropriated the intellectual property rights of their former employers or other third parties. Our 
competitors in both the United States and abroad, many of which have substantially greater resources and have made 
substantial investments in patent portfolios and competing technologies, may have applied for or obtained or may in 
the future apply for and obtain, patents that will prevent, limit, or otherwise interfere with our ability to make, use, 
sell, and/or export our products. For example, our major competitors, Medtronic, Boston Scientific and Abbott 

39 

 
Laboratories (which recently acquired St. Jude Medical), each have significant patent portfolios covering systems, 
sub-systems, methods, and manufacturing processes. These competitors may have one or more patents for which 
they can threaten and/or initiate patent infringement actions against us and/or any of our third-party suppliers. Our 
ability to defend ourselves and/or our third-party suppliers may be limited by our financial and human resources, the 
availability of reasonable defenses, and the ultimate acceptance of our defenses by the courts or juries. Further, if 
such patents are successfully asserted against us, this may result in an adverse impact on our business, including 
injunctions, damages and/or attorneys’ fees. From time to time and in the ordinary course of business, we may 
develop non-infringement and/or invalidity positions with respect to third-party patents, which may or not be 
ultimately adjudicated as successful by a judge or jury if such patents were asserted against us. 

We may receive in the future, particularly as a public company, communications from patent holders, 

including non-practicing entities, alleging infringement of patents or other intellectual property rights or 
misappropriation of trade secrets, or offering licenses to such intellectual property. Any claims that we assert against 
perceived infringers could also provoke these parties to assert counterclaims against us alleging that we infringe 
their intellectual property rights. At any given time, we may be involved as either a plaintiff or a defendant in a 
number of patent infringement actions, the outcomes of which may not be known for prolonged periods of time. We 
may also become involved in disputes with others regarding the ownership of intellectual property rights. For 
example, we jointly develop intellectual property with certain parties, and disagreements may therefore arise as to 
the ownership of the intellectual property developed pursuant to these relationships. If we are unable to resolve these 
disputes, we could lose valuable intellectual property rights. 

The large number of patents, the rapid rate of new patent applications and issuances, the complexities of the 

technologies involved and the uncertainty of litigation significantly increase the risks related to any patent litigation. 
Any potential intellectual property litigation also could force us to do one or more of the following: 

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stop selling, making, using, or exporting products that use the disputed intellectual property; 

obtain a license from the intellectual property owner to continue selling, making, exporting, or using 
products, which license may require substantial royalty payments and may not be available on 
reasonable terms, or at all; 

incur significant legal expenses; 

pay substantial damages or royalties to the party whose intellectual property rights we may be found to 
be infringing, potentially including treble damages if the court finds that the infringement was willful; 

if a license is available from a third-party, we may have to pay substantial royalties, upfront fees or 
grant cross-licenses to intellectual property rights for our products and services; 

pay the attorney fees and costs of litigation to the party whose intellectual property rights we may be 
found to be infringing; 

find non-infringing substitute products, which could be costly and create significant delay due to the 
need for FDA regulatory clearance; 

find alternative supplies for infringing products or processes, which could be costly and create 
significant delay due to the need for FDA regulatory clearance; and/or 

redesign those products or processes that infringe any third-party intellectual property, which could be 
costly, disruptive, and/or infeasible. 

From time to time, we may be subject to legal proceedings and claims in the ordinary course of business with 

respect to intellectual property. In particular, on November 28, 2016, we filed a lawsuit for patent infringement 
against units of Boston Scientific asserting that Boston Scientific is infringing our patents covering inventions 
relating to our Senza system and HF10 therapy. For more information, see the section titled “Legal Proceedings” 
included under Part I, Item 3 of this Annual Report. Even if resolved in our favor, litigation or other legal 
proceedings relating to intellectual property claims may cause us to incur significant expenses, and could distract our 
technical and management personnel from their normal responsibilities. In addition, there could be public 
announcements of the results of hearings, motions or other interim proceedings or developments, and if securities 

40 

 
analysts or investors perceive these results to be negative, it could have a material adverse effect on the price of our 
common stock and the value of the 1.75% convertible senior notes due 2021 (the 2021 Notes). Finally, any 
uncertainties resulting from the initiation and continuation of any litigation could have a material adverse effect on 
our ability to raise the funds necessary to continue our operations. 

If any of the foregoing occurs, we may have to withdraw existing products from the market or may be unable 

to commercialize one or more of our products, all of which could have a material adverse effect on our business, 
results of operations and financial condition. Any litigation or claim against us, even those without merit, may cause 
us to incur substantial costs, and could place a significant strain on our financial resources, divert the attention of 
management from our core business and harm our reputation. Further, as the number of participants in the 
neuromodulation industry grows, the possibility of intellectual property infringement claims against us increases. 

In addition, we may indemnify our customers, suppliers and international distributors against claims relating 

to the infringement of the intellectual property rights of third parties relating to our products, methods, and/or 
manufacturing processes. Third parties may assert infringement claims against our customers, suppliers, or 
distributors. These claims may require us to initiate or defend protracted and costly litigation on behalf of our 
customers, suppliers or distributors, regardless of the merits of these claims. If any of these claims succeed, we may 
be forced to pay damages on behalf of our customers, suppliers, or distributors or may be required to obtain licenses 
for the products they use. If we cannot obtain all necessary licenses on commercially reasonable terms, our 
customers may be forced to stop using our products, or our suppliers may be forced to stop providing us with 
products. 

Similarly, interference or derivation proceedings provoked by third parties or brought by the USPTO or any 
foreign patent authority may be necessary to determine the priority of inventions or other matters of inventorship 
with respect to our patents or patent applications. An unfavorable outcome in these or any other such proceedings 
could require us to cease using the related technology or to attempt to license rights to it from the prevailing party. 
Our business could be harmed if the prevailing party does not offer us a license on commercially reasonable terms, 
if any license is offered at all. 

We may also become involved in other proceedings, such as re-examination or opposition proceedings, before 

the USPTO or its foreign counterparts relating to our intellectual property or the intellectual property rights of 
others. For example, two of our competitors, Boston Scientific and Medtronic, have filed oppositions in the 
European Union with respect to certain of our patents. Defending our position in proceedings such as these will 
require management’s time and attention, as well as financial costs. Given the competitive environment in which we 
operate, we expect additional challenges to our intellectual property portfolio as we continue commercialization of 
Senza in the United States. An unfavorable outcome in these or any other such proceedings could cause us to lose 
valuable intellectual property rights and/or be unable to enforce our intellectual property rights, which could invite 
increased competition thereby materially harming our business. 

Changes in patent law could diminish the value of patents in general, thereby impairing our ability to protect our 
existing and future products. 

Patent reform legislation could increase the uncertainties and costs surrounding the prosecution of our patent 

applications and the enforcement or defense of our issued patents. On September 16, 2011, the Leahy-Smith 
America Invents Act, or the Leahy-Smith Act, was signed into law. The Leahy-Smith Act includes a number of 
significant changes to U.S. patent law. These include provisions that affect the way patent applications are 
prosecuted, redefine prior art and may affect patent litigation. The changes also switched the United States patent 
system from a “first-to-invent” system to a “first-to-file” system. Under a “first-to-file” system, assuming the other 
requirements for patentability are met, the first inventor to file a patent application generally will be entitled to the 
patent on an invention regardless of whether another inventor had made the invention earlier. The USPTO recently 
developed new regulations and procedures to govern administration of the Leahy- Smith Act, and many of the 
substantive changes to patent law associated with the Leahy-Smith Act, in particular, the first-to-file provisions, 
only became effective on March 16, 2013. Accordingly, it is not clear what, if any, impact the Leahy-Smith Act will 
have on the operation of our business. The Leahy-Smith Act and its implementation could increase the uncertainties 
and costs surrounding the prosecution of our patent applications and the enforcement or defense of our issued 
patents, all of which could have a material adverse effect on our business and financial condition. 

41 

 
In addition, patent reform legislation may pass in the future that could lead to additional uncertainties and 
increased costs surrounding the prosecution, enforcement and defense of our patents and applications. Furthermore, 
the U.S. Supreme Court and the U.S. Court of Appeals for the Federal Circuit have made, and will likely continue to 
make, changes in how the patent laws of the United States are interpreted. Similarly, foreign courts have made, and 
will likely continue to make, changes in how the patent laws in their respective jurisdictions are interpreted. We 
cannot predict future changes in the interpretation of patent laws or changes to patent laws that might be enacted into 
law by United States and foreign legislative bodies. Those changes may materially affect our patents or patent 
applications and our ability to obtain additional patent protection in the future. 

Obtaining and maintaining patent protection depends on compliance with various procedural, document 
submission, fee payment and other requirements imposed by governmental patent agencies, and our patent 
protection could be reduced or eliminated for non-compliance with these requirements. 

The USPTO and various foreign governmental patent agencies require compliance with a number of 

procedural, documentary, fee payment and other similar provisions during the patent application process. In 
addition, periodic maintenance fees on issued patents often must be paid to the USPTO and foreign patent agencies 
over the lifetime of the patent. While an unintentional lapse can in many cases be cured by payment of a late fee or 
by other means in accordance with the applicable rules, there are situations in which noncompliance can result in 
abandonment or lapse of the patent or patent application, resulting in partial or complete loss of patent rights in the 
relevant jurisdiction. Non-compliance events that could result in abandonment or lapse of a patent or patent 
application include, but are not limited to, failure to respond to official actions within prescribed time limits, non-
payment of fees and failure to properly legalize and submit formal documents. If we fail to maintain the patents and 
patent applications covering our products or procedures, we may not be able to stop a competitor from marketing 
products that are the same as or similar to our own, which would have a material adverse effect on our business. 

We may not be able to adequately protect our intellectual property rights throughout the world. 

Filing, prosecuting and defending patents on our products in all countries throughout the world would be 

prohibitively expensive. The requirements for patentability may differ in certain countries, particularly developing 
countries, and the breadth of patent claims allowed can be inconsistent. In addition, the laws of some foreign 
countries may not protect our intellectual property rights to the same extent as laws in the United States. 
Consequently, we may not be able to prevent third parties from practicing our inventions in all countries outside the 
United States. Competitors may use our technologies in jurisdictions where we have not obtained patent protection 
to develop their own products and, further, may export otherwise infringing products to territories in which we have 
patent protection that may not be sufficient to terminate infringing activities. 

We do not have patent rights in certain foreign countries in which a market may exist. Moreover, in foreign 

jurisdictions where we do have patent rights, proceedings to enforce such rights could result in substantial costs and 
divert our efforts and attention from other aspects of our business, could put our patents at risk of being invalidated 
or interpreted narrowly, and our patent applications at risk of not issuing. Additionally, such proceedings could 
provoke third parties to assert claims against us. We may not prevail in any lawsuits that we initiate, and if we do 
prevail, the damages or other remedies awarded, if any, may not be commercially meaningful. Thus, we may not be 
able to stop a competitor from marketing and selling in foreign countries products that are the same as or similar to 
our products, and our competitive position in the international market would be harmed. 

We may be subject to damages resulting from claims that we or our employees have wrongfully used or disclosed 
alleged trade secrets of our competitors or are in breach of non-competition or non-solicitation agreements with 
our competitors. 

We could in the future be subject to claims that we or our employees have inadvertently or otherwise used or 

disclosed alleged trade secrets or other proprietary information of former employers or competitors. In addition, 
many of our executive officers and key employees, as well as our Chairman of the Board, have worked for our 
major competitors (or companies acquired by these competitors), which include Boston Scientific, Medtronic and 
Abbott Laboratories (which recently acquired St. Jude Medical). Although we have procedures in place that seek to 
prevent our employees and consultants from using the intellectual property, proprietary information, know-how or 
trade secrets of others in their work for us, we may in the future be subject to claims that we caused an employee to 

42 

 
breach the terms of his or her non-competition or non-solicitation agreement, or that we or these individuals have, 
inadvertently or otherwise, used or disclosed the alleged trade secrets or other proprietary information of a former 
employer or competitor. Litigation may be necessary to defend against these claims. Even if we are successful in 
defending against these claims, litigation could result in substantial costs and could be a distraction to management. 
If our defense to those claims fails, in addition to paying monetary damages, a court could prohibit us from using 
technologies or features that are essential to our products, if such technologies or features are found to incorporate or 
be derived from the trade secrets or other proprietary information of the former employers. An inability to 
incorporate technologies or features that are important or essential to our products would have a material adverse 
effect on our business, and may prevent us from selling our products or from practicing our processes. In addition, 
we may lose valuable intellectual property rights or personnel. Moreover, any such litigation or the threat thereof 
may adversely affect our ability to hire employees or contract with independent sales representatives. A loss of key 
personnel or their work product could hamper or prevent our ability to commercialize our products, which could 
have an adverse effect on our business, results of operations and financial condition. 

If our trademarks and trade names are not adequately protected, then we may not be able to build name 
recognition in our markets of interest and our business may be adversely affected. 

Our registered or unregistered trademarks or trade names may be challenged, infringed, circumvented, 
declared generic or determined to be infringing on other marks. We may not be able to protect our rights in these 
trademarks and trade names, which we need in order to build name recognition with potential partners or customers 
in our markets of interest. In addition, third parties have registered trademarks similar and identical to our 
trademarks in foreign jurisdictions, and may in the future file for registration of such trademarks. If they succeed in 
registering or developing common law rights in such trademarks, and if we were not successful in challenging such 
third-party rights, we may not be able to use these trademarks to market our products in those countries. In any case, 
if we are unable to establish name recognition based on our trademarks and trade names, then we may not be able to 
compete effectively and our business may be adversely affected. 

If we are unable to protect the confidentiality of our trade secrets, our business and competitive position may be 
harmed. 

In addition to patent and trademark protection, we also rely on trade secrets, including unpatented know-how, 

technology and other proprietary information, to maintain our competitive position. We seek to protect our trade 
secrets, in part, by entering into non-disclosure and confidentiality agreements with parties who have access to them, 
such as our consultants and vendors, or our former or current employees. We also enter into confidentiality and 
invention or patent assignment agreements with our employees and consultants. Despite these efforts, however, any 
of these parties may breach the agreements and disclose our trade secrets and other unpatented or unregistered 
proprietary information, and once disclosed, we are likely to lose trade secret protection. Monitoring unauthorized 
uses and disclosures of our intellectual property is difficult, and we do not know whether the steps we have taken to 
protect our intellectual property will be effective. In addition, we may not be able to obtain adequate remedies for 
any such breaches. Enforcing a claim that a party illegally disclosed or misappropriated a trade secret is difficult, 
expensive and time-consuming, and the outcome is unpredictable. In addition, some courts inside and outside the 
United States are less willing or unwilling to enforce trade secret protection. 

Further, our competitors may independently develop knowledge, methods and know-how similar, equivalent, 
or superior to our proprietary technology. Competitors could purchase our products and attempt to replicate some or 
all of the competitive advantages we derive from our development efforts, willfully infringe our intellectual property 
rights, design around our protected technology or develop their own competitive technologies that fall outside of our 
intellectual property rights. In addition, our key employees, consultants, suppliers or other individuals with access to 
our proprietary technology and know-how may incorporate that technology and know-how into projects and 
inventions developed independently or with third parties. As a result, disputes may arise regarding the ownership of 
the proprietary rights to such technology or know-how, and any such dispute may not be resolved in our favor. If 
any of our trade secrets were to be lawfully obtained or independently developed by a competitor, we would have no 
right to prevent them, or those to whom they communicate it, from using that technology or information to compete 
with us and our competitive position could be adversely affected. If our intellectual property is not adequately 
protected so as to protect our market against competitors’ products and methods, our competitive position could be 
adversely affected, as could our business. 

43 

 
Risks Related to our Financial and Operating Results 

We may choose, or need, to obtain additional funds in the future, and these funds may not be available on 
acceptable terms or at all. 

Our operations have consumed substantial amounts of cash since inception, and we anticipate our expenses 

will increase as we continue to build a commercial sales force in the United States, investigate the use of our HF10 
therapy for the treatment of other chronic pain conditions, continue to otherwise grow our business and continue to 
operate as a public company. In particular, we believe that we will continue to expend substantial resources for the 
foreseeable future on the commercialization of Senza in the United States, as well as the growth of our sales and 
marketing efforts and sales representative training, seeking additional foreign regulatory approvals, the preparation 
and submission of regulatory filings and the clinical development of any other product candidates or indications we 
may choose to pursue. These expenditures will also include costs associated with manufacturing and supply as well 
as marketing and selling Senza in the United States and elsewhere, and any other future products approved for sale, 
R&D, conducting preclinical studies and clinical trials and obtaining regulatory approvals. 

We believe that our growth will depend, in part, on our ability to fund our commercialization efforts, 
particularly in the United States, and our efforts to develop Senza and our HF10 therapy for the treatment of 
additional chronic pain indications and develop technology complementary to our current product. In order to 
further enhance our R&D efforts, pursue product expansion opportunities or acquire a new business or products that 
are complementary to our business, we may choose to seek additional funds. If we are unable to raise funds on 
favorable terms, or at all, the long-term growth of our business may be negatively impacted. As a result, we may be 
unable to compete effectively. Our cash requirements in the future may be significantly different from our current 
estimates and depend on many factors, including: 

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the costs of commercializing Senza in the United States and elsewhere, including costs associated with 
product sales, marketing, manufacturing and distribution; 

the cost of filing, prosecuting, defending and enforcing any patent claims and other intellectual property 
rights, including, in particular, the costs of enforcing our patent rights in the action we filed against 
Boston Scientific and in defending against Boston Scientific’s action against us; 

the R&D activities we intend to undertake in order to expand the chronic pain indications and product 
enhancements that we intend to pursue; 

whether or not we pursue acquisitions or investments in businesses, products or technologies that are 
complementary to our current business; 

the degree and rate of market acceptance of Senza in the United States and elsewhere; 

changes or fluctuations in our inventory supply needs and forecasts of our supply needs; 

our need to implement additional infrastructure and internal systems; 

our ability to hire additional personnel to support our operations as a public company; and 

the emergence of competing technologies or other adverse market developments. 

To finance these activities, we may seek funds through borrowings or through additional rounds of financing, 
including private or public equity or debt offerings and collaborative arrangements with corporate partners. We may 
be unable to raise funds on favorable terms, or at all. 

The sale of additional equity or convertible debt securities could result in additional dilution to our 
stockholders. If we borrow additional funds or issue debt securities, these securities could have rights superior to 
holders of our common stock and the 2021 Notes and could contain covenants that will restrict our operations. We 
might have to obtain funds through arrangements with collaborative partners or others that may require us to 
relinquish rights to our technologies, product candidates, or products that we otherwise would not relinquish. If we 
do not obtain additional resources, our ability to capitalize on business opportunities will be limited, we may be 
unable to compete effectively and the growth of our business will be harmed. 

44 

 
Our operating results may vary significantly from quarter to quarter, which may negatively impact our stock 
price in the future. 

Our quarterly revenue and results of operations may fluctuate from quarter to quarter due to, among others, the 

following reasons: 

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physician and payor acceptance of Senza and our HF10 therapy; 

the timing, expense and results of our commercialization efforts in the United States and elsewhere, 
R&D activities, clinical trials and regulatory approvals; 

fluctuations in our expenses associated with inventory buildup or write-downs from analyzing our 
inventory for obsolesce or conformity with our product requirements; 

difficulties in collecting receivables related to our sales in the United States; 

fluctuations in the expenses related to pursuing and defending our ongoing lawsuits with Boston 
Scientific; 

fluctuations in expenses as a result of expanding our commercial operations and operating as a public 
company; 

the introduction of new products and technologies by our competitors; 

the productivity of our sales representatives; 

supplier, manufacturing or quality problems with our products; 

the timing of stocking orders from our distributors; 

changes in our pricing policies or in the pricing policies of our competitors or suppliers; and 

changes in coverage amounts or government and third-party payors’ reimbursement policies. 

Because of these and other factors, it is likely that in some future period our operating results will not meet 

investor expectations or those of public market analysts. 

Any unanticipated change in revenues or operating results is likely to cause our stock price to fluctuate. New 

information may cause investors and analysts to revalue our business, which could cause a decline in our stock 
price. 

We are required to maintain high levels of inventory, which could consume a significant amount of our 
resources, reduce our cash flows and lead to inventory impairment charges. 

As a result of the need to maintain substantial levels of inventory, we are subject to the risk of inventory 
obsolescence and expiration, which may lead to inventory impairment charges. Our products consist of a substantial 
number of individual components. In order to market and sell Senza effectively, we often must maintain high levels 
of inventory. In particular, as we continue our commercial launch of Senza in the United States, we intend to 
substantially increase our levels of inventory in order to meet our estimated demand and, as a result, incur 
significant expenditures associated with such increases in our inventory. The manufacturing process requires lengthy 
lead times, during which components of our products may become obsolete, and we may over- or under-estimate the 
amount needed of a given component, in which case we may expend extra resources or be constrained in the amount 
of end product that we can produce. As compared to direct manufacturers, our dependence on third-party 
manufacturers exposes us to greater lead times increasing our risk of inventory obsolescence comparatively. 
Furthermore, our products have a limited shelf life due to sterilization requirements, and part or all of a given 
product or component may expire and its value would become impaired and we would be required to record an 
impairment charge. In addition, we have also experienced inventory write-downs as a result of inventory that did not 
meet our product requirements. If our estimates of required inventory are too high, we may be exposed to further 
inventory obsolescence risk. In the event that a substantial portion of our inventory becomes obsolete or expires, or 
in the event we experience a supply chain imbalance as described above, it could have a material adverse effect on 

45 

 
our earnings and cash flows due to the resulting costs associated with the inventory impairment charges and costs 
required to replace such inventory. 

The seasonality of our business creates variance in our quarterly revenue, which makes it difficult to compare or 
forecast our financial results. 

Our revenue fluctuates on a seasonal basis, which affects the comparability of our results between periods. For 

example, in certain years we have historically experienced lower sales in the summer months and around the 
holidays, primarily due to the buying patterns and implant volumes of our distributors, hospitals and clinics. These 
seasonal variations are difficult to predict accurately, may vary amongst different markets, and at times may be 
entirely unpredictable, which introduce additional risk into our business as we rely upon forecasts of customer 
demand to build inventory in advance of anticipated sales. In addition, we believe our limited history 
commercializing our products has, in part, made our seasonal patterns more difficult to discern, making it more 
difficult to predict future seasonal patterns. 

We are subject to risks associated with currency fluctuations, and changes in foreign currency exchange rates 
could impact our results of operations. 

A portion of our business is located outside the United States and, as a result, we generate revenue and incur 

expenses denominated in currencies other than the U.S. dollar, a majority of which is denominated in Euros and 
Australian Dollars. In the first half of 2015, and all of 2014 and 2013, nearly all of our total revenue was 
denominated in foreign currencies. As a result, changes in the exchange rates between such foreign currencies and 
the U.S. dollar could materially impact our reported results of operations and distort period to period comparisons. 
Fluctuations in foreign currency exchange rates also impact the reporting of our receivables and payables in non-
U.S. currencies. As a result of such foreign currency fluctuations, it could be more difficult to detect underlying 
trends in our business and results of operations. In addition, to the extent that fluctuations in currency exchange rates 
cause our results of operations to differ from our expectations or the expectations of our investors, the trading price 
of our common stock and the value of the 2021 Notes could be adversely affected. 

In the future, we may engage in exchange rate hedging activities in an effort to mitigate the impact of 

exchange rate fluctuations. If our hedging activities are not effective, changes in currency exchange rates may have a 
more significant impact on our results of operations. 

Our ability to use our net operating losses and tax credits to offset future taxable income and taxes may be 
subject to certain limitations. 

In general, under Section 382 of the U.S. Internal Revenue Code of 1986, as amended, a corporation that 

undergoes an “ownership change” is subject to limitations on its ability to utilize its pre-change net operating loss 
(NOL) carryforwards and other tax attributes, such as research and development tax credits to offset future taxable 
income and taxes. 

As a result of our June 2015 underwritten public offering, we have experienced a Section 382 “ownership 

change.” We currently believe that this “ownership change” will not inhibit our ability to utilize our NOLs.  
However, as a result of any potential future “ownership changes,” or if we do not generate sufficient taxable income 
in the future, we may not be able to utilize a material portion of our NOLs and tax credits, even if we achieve 
profitability. If we are limited in our ability to use our NOLs and tax credits in future years in which we have taxable 
income, we will pay more taxes than if we were able to fully utilize our NOLs and tax credits. This could materially 
and adversely affect our results of operations. As of December 31, 2016, we had federal and state NOLs of $224.7 
million and $77.3 million, respectively, available to offset future taxable income due to prior period losses, which if 
not utilized will begin to expire in 2026 for federal purposes and begin to expire in 2017 for state purposes. 

46 

 
Risks Related to Regulation of our Industry 

Senza is subject to extensive governmental regulation, and our failure to comply with applicable requirements 
could cause our business to suffer. 

The medical device industry is regulated extensively by governmental authorities, principally the FDA and 

corresponding state and foreign regulatory agencies and authorities, such as the EU legislative bodies and the EEA 
Member State Competent Authorities. The FDA and other U.S., EEA and foreign governmental agencies and 
authorities regulate and oversee, among other things, with respect to medical devices: 

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design, development and manufacturing; 

testing, labeling, content and language of instructions for use and storage; 

clinical trials; 

product safety; 

marketing, sales and distribution; 

pre-market regulatory clearance and approval; 

conformity assessment procedures; 

record-keeping procedures; 

advertising and promotion; 

recalls and other field safety corrective actions; 

post-market surveillance, including reporting of deaths or serious injuries and malfunctions that, if they 
were to recur, could lead to death or serious injury; 

post-market studies; and 

product import and export. 

The laws and regulations to which we are subject are complex and have tended to become more stringent over 

time. Legislative or regulatory changes could result in restrictions on our ability to carry on or expand our 
operations, higher than anticipated costs or lower than anticipated sales. 

Our failure to comply with U.S. federal and state regulations or EEA or other foreign regulations applicable in 

the countries where we operate could lead to the issuance of warning letters or untitled letters, the imposition of 
injunctions, suspensions or loss of regulatory clearance or approvals, product recalls, termination of distribution, 
product seizures or civil penalties. In the most extreme cases, criminal sanctions or closure of our manufacturing 
facilities are possible. If any of these risks materialize, our business would be adversely affected. 

Our business is subject to extensive governmental regulation that could make it more expensive and time 
consuming for us to expand the potential indications for which Senza is approved or introduce new or improved 
products. 

Our products must comply with regulatory requirements imposed by the FDA in the United States and similar 

agencies in foreign jurisdictions. These requirements involve lengthy and detailed laboratory and clinical testing 
procedures, sampling activities, extensive agency review processes, and other costly and time-consuming 
procedures. It often takes several years to satisfy these requirements, depending on the complexity and novelty of 
the product. We also are subject to numerous additional licensing and regulatory requirements relating to safe 
working conditions, manufacturing practices, environmental protection, fire hazard control and disposal of 
hazardous or potentially hazardous substances. Some of the most important requirements we must comply with 
include: 

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FFDCA and the FDA’s implementing regulations (Title 21 CFR); 

European Union CE mark requirements; 

47 

 
  Medical Device Quality Management System Requirements (ISO 13485:2003); 

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Occupational Safety and Health Administration requirements; and 

California Department of Health Services requirements. 

Government regulation may impede our ability to conduct clinical studies and to manufacture and sell our 

existing and future products. Government regulation also could delay our marketing of new products for a 
considerable period of time and impose costly procedures on our activities. Foreign regulatory agencies may not 
approve Senza and any of our future products on a timely basis, if at all. Any delay in obtaining, or failure to obtain, 
such approvals could negatively impact our marketing of any future products and reduce our product revenues. 

Our products remain subject to strict regulatory controls on manufacturing, marketing and use. We may be 

forced to modify or recall a product after release in response to regulatory action or unanticipated difficulties 
encountered in general use. Any such action could have a material effect on the reputation of our products and on 
our business and financial position. 

Further, regulations may change, and any additional regulation could limit or restrict our ability to use any of 
our technologies, which could harm our business. For example, in December 2016, the 21st Century Cures Act, or 
Cures Act, was signed into law.  The Cures Act, among other things, is intended to modernize the regulation of 
medical devices and spur innovation, but its ultimate implementation remains unclear.  We could also be subject to 
new international, federal, state or local regulations that could affect our R&D programs and harm our business in 
unforeseen ways. If this happens, we may have to incur significant costs to comply with such laws and regulations, 
which will harm our results of operations. 

We also cannot predict the likelihood, nature or extent of government regulation that may arise from future 

legislation or administrative or executive action, either in the United States or abroad. For example, certain policies 
of the Trump administration may impact our business and industry.  Namely, the Trump administration has taken 
several executive actions, including the issuance of a number of Executive Orders, that could impose significant 
burdens on, or otherwise materially delay, the FDA’s ability to engage in routine regulatory and oversight activities 
such as implementing statutes through rulemaking, issuance of guidance, and review and approval of marketing 
applications.  Notably, on January 23, 2017, President Trump ordered a hiring freeze for all executive departments 
and agencies, including the FDA, which prohibits the FDA from filling employee vacancies or creating new 
positions.  Under the terms of the order, the freeze will remain in effect until implementation of a plan to be 
recommended by the Director for the Office of Management and Budget, or OMB, in consultation with the Director 
of the Office of Personnel Management, to reduce the size of the federal workforce through attrition. An under-
staffed FDA could result in delays in FDA’s responsiveness or in its ability to review submissions or applications, 
issue regulations or guidance or implement or enforce regulatory requirements in a timely fashion or at all.  
Moreover, on January 30, 2017, President Trump issued an Executive Order, applicable to all executive agencies, 
including the FDA, that requires that for each notice of proposed rulemaking or final regulation to be issued in fiscal 
year 2017, the agency shall identify at least two existing regulations to be repealed, unless prohibited by law.  These 
requirements are referred to as the “two-for-one” provisions. This Executive Order includes a budget neutrality 
provision that requires the total incremental cost of all new regulations in the 2017 fiscal year, including repealed 
regulations, to be no greater than zero, except in limited circumstances.  For fiscal years 2018 and beyond, the 
Executive Order requires agencies to identify regulations to offset any incremental cost of a new regulation and 
approximate the total costs or savings associated with each new regulation or repealed regulation.  In interim 
guidance issued by the Office of Information and Regulatory Affairs within OMB on February 2, 2017, the 
administration indicates that the “two-for-one” provisions may apply not only to agency regulations, but also to 
significant agency guidance documents.  It is difficult to predict how these requirement will be implemented, and the 
extent to which they will impact the FDA’s ability to exercise its regulatory authority.  If these executive actions 
impose constraints on FDA’s ability to engage in oversight and implementation activities in the normal course, our 
business may be negatively impacted. 

In September 2012, the European Commission published proposals for the revision of the EU regulatory 

framework for medical devices. The proposals would replace the Medical Devices Directive and the Active 
Implantable Medical Devices Directive with two new regulations: the Medical Devices Regulation and the In-Vitro 

48 

 
Diagnostic Medical Devices Regulation. Unlike directives, which must be implemented into the national laws of the 
EEA member States, the regulations would be directly applicable, i.e., without the need for adoption of EEA 
member State laws implementing them, in all EEA member States and are intended to eliminate current differences 
in the regulation of medical devices among EEA member States. 

The Medical Devices Regulation and the In-Vitro Diagnostic Medical Devices Regulation are expected to be 

adopted in the first quarter of 2017. However, the Medical Devices Regulation, which is the regulation directly 
applicable to our products, will only become applicable three years after publication in the Office Journal of the 
European Union. Once in effect, the Medical Devices Regulation will, among other things: 

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strengthen the rules on placing devices on the market and reinforce surveillance once they are available; 

establish explicit provisions on manufacturers' responsibilities for the follow-up of the quality, 
performance and safety of devices placed on the market;  

improve the traceability of medical devices throughout the supply chain to the end-user or patient 
through a unique identification number;  

set up a central database to provide patients, healthcare professionals and the public with comprehensive 
information on products available in the EU;  

strengthened rules for the assessment of certain high-risk devices, such as implants, which may have to 
undergo an additional check by experts before they are placed on the market.  

These modifications may have an impact on the way we conduct our business in the EEA.  

Senza is subject to extensive governmental regulation in foreign jurisdictions, such as Europe, and our failure to 
comply with applicable requirements could cause our business to suffer. 

In the EEA, Senza must comply with the Essential Requirements laid down in Annex I to the EU Active 
Implantable Medical Devices Directive. Compliance with these requirements is a prerequisite to be able to affix the 
CE mark to Senza, without which Senza cannot be marketed or sold in the EEA. To demonstrate compliance with 
the Essential Requirements and obtain the right to affix the CE Mark to Senza, we must undergo a conformity 
assessment procedure, which varies according to the type of medical device and its classification. Except for low 
risk medical devices (Class I with no measuring function and which are not sterile), where the manufacturer can 
issue an EC Declaration of Conformity based on a self-assessment of the conformity of its products with the 
Essential Requirements, a conformity assessment procedure requires the intervention of a Notified Body, which is 
an organization designated by a competent authority of an EEA country to conduct conformity assessments. 
Depending on the relevant conformity assessment procedure, the Notified Body would audit and examine the 
Technical File and the quality system for the manufacture, design and final inspection of our devices. The Notified 
Body issues a CE Certificate of Conformity following successful completion of a conformity assessment procedure 
conducted in relation to the medical device and its manufacturer and their conformity with the Essential 
Requirements. This Certificate entitles the manufacturer to affix the CE mark to its medical devices after having 
prepared and signed a related EC Declaration of Conformity. 

As a general rule, demonstration of conformity of medical devices and their manufacturers with the Essential 

Requirements must be based, among other things, on the evaluation of clinical data supporting the safety and 
performance of the products during normal conditions of use. Specifically, a manufacturer must demonstrate that the 
device achieves its intended performance during normal conditions of use and that the known and foreseeable risks, 
and any adverse events, are minimized and acceptable when weighed against the benefits of its intended 
performance, and that any claims made about the performance and safety of the device (e.g., product labeling and 
instructions for use) are supported by suitable evidence. This assessment must be based on clinical data, which can 
be obtained from (1) clinical studies conducted on the devices being assessed, (2) scientific literature from similar 
devices whose equivalence with the assessed device can be demonstrated or (3) both clinical studies and scientific 
literature. With respect to active implantable medical devices or Class III devices, the manufacturer must conduct 
clinical studies to obtain the required clinical data, unless reliance on existing clinical data from equivalent devices 
can be justified. The conduct of clinical studies in the EEA is governed by detailed regulatory obligations. These 
may include the requirement of prior authorization by the competent authorities of the country in which the study 

49 

 
takes place and the requirement to obtain a positive opinion from a competent Ethics Committee. This process can 
be expensive and time-consuming. 

In order to continue to sell Senza in Europe, we must maintain our CE Mark and continue to comply with 
certain EU Directives. Our failure to continue to comply with applicable foreign regulatory requirements, including 
those administered by authorities of the EEA countries, could result in enforcement actions against us, including 
refusal, suspension or withdrawal of our CE Certificates of Conformity by the BSI, which could impair our ability to 
market products in the EEA in the future. 

The misuse or off-label use of our product may harm our image in the marketplace, result in injuries that lead to 
product liability suits, which could be costly to our business, or result in costly investigations and sanctions from 
the FDA and other regulatory bodies if we are deemed to have engaged in off-label promotion. 

Senza has been approved for marketing in the United States, CE Marked in the EEA and approved by the 
TGA in Australia for specific treatments and anatomies. We may only promote or market the Senza SCS system for 
its specifically approved indications as described on the approved label. We train our marketing and sales force 
against promoting our products for uses outside of the approved indications for use, known as “off-label uses.” We 
cannot, however, prevent a physician from using our product off-label, when in the physician’s independent 
professional medical judgment he or she deems the use of the product in the non-approved indication as appropriate. 
There may be increased risk of injury to patients if physicians attempt to use our product off-label. Furthermore, the 
use of our product for indications other than those approved by the applicable regulatory body may not effectively 
treat such conditions, which could harm our reputation in the marketplace among physicians and patients. 

Physicians may also misuse our product or use improper techniques if they are not adequately trained, 
potentially leading to injury and an increased risk of product liability. If our product is misused or used with 
improper technique, we may become subject to costly litigation by our customers or their patients. Product liability 
claims could divert management’s attention from our core business, be expensive to defend, and result in sizable 
damage awards against us that may not be covered by insurance. In addition, if the FDA determines that our 
promotional materials, training or physician support activities constitute promotion of an off-label use, it could 
request that we modify our training, promotional materials or physician support activities or subject us to regulatory 
or enforcement actions, including the issuance of an untitled letter, a warning letter, injunction, seizure, civil fine or 
criminal penalties. It is also possible that other federal, state or foreign enforcement authorities might take action if 
they consider our business activities to constitute promotion of an off-label use, which could result in significant 
penalties, including, but not limited to, criminal, civil and/or administrative penalties, damages, fines, disgorgement, 
exclusion from participation in government healthcare programs, and the curtailment of our operations. Further, 
regulators or legislators may also enhance the enforcement of, and attempt to curtail, any off-label use by physicians 
of medical devices in the future. Any of these events could significantly harm our business and results of operations 
and cause our stock price to decline. 

Further, the advertising and promotion of our products is subject to EEA Member States laws implementing 

Directive 93/42/EEC concerning Medical Devices (the EU Medical Devices Directive), Directive 2006/114/EC 
concerning misleading and comparative advertising, and Directive 2005/29/EC on unfair commercial practices, as 
well as other EEA Member State legislation governing the advertising and promotion of medical devices. EEA 
Member State legislation may also restrict or impose limitations on our ability to advertise our products directly to 
the general public. In addition, voluntary EU and national Codes of Conduct provide guidelines on the advertising 
and promotion of our products and may impose limitations on our promotional activities with healthcare 
professionals. 

Senza may in the future be subject to notifications, recalls, or voluntary market withdrawals that could harm our 
reputation, business and financial results. 

The FDA, EEA Competent Authorities and similar foreign governmental authorities have the authority to 

require the recall of commercialized products in the event of material deficiencies or defects in design or 
manufacture that could affect patient safety. In the case of the FDA, the authority to require a recall must be based 
on an FDA finding that there is a reasonable probability that the device would cause serious adverse health 
consequences or death. Manufacturers may, under their own initiative, conduct a product notification or recall to 

50 

 
inform physicians of changes to instructions for use, or if a deficiency in a device is found or suspected. A 
government-mandated recall or voluntary recall by us or one of our distributors could occur as a result of component 
failures, manufacturing errors, design or labeling defects or other issues. Recalls, which include certain notifications 
and corrections as well as removals, of Senza could divert managerial and financial resources and could have an 
adverse effect on our financial condition, harm our reputation with customers, and reduce our ability to achieve 
expected revenue. 

In addition, the manufacturing of our products is subject to extensive post-market regulation by the FDA and 

foreign regulatory authorities, and any failure by us or our contract manufacturers or suppliers to comply with 
regulatory requirements could result in recalls, facility closures, and other penalties. We and our suppliers and 
contract manufacturers are subject to the QSR, and comparable foreign regulations which govern the methods used 
in, and the facilities and controls used for, the design, manufacture, quality assurance, labeling, packaging, 
sterilization, storage, shipping, and servicing of medical devices. These regulations are enforced through periodic 
inspections of manufacturing facilities. Any manufacturing issues at our or our suppliers’ or contract manufacturers’ 
facilities, including failure to comply with regulatory requirements, may result in warning or untitled letters, 
manufacturing restrictions, voluntary or mandatory recalls or corrections, fines, withdrawals of regulatory clearances 
or approvals, product seizures, injunctions, or the imposition of civil or criminal penalties, which would adversely 
affect our business results and prospects. 

We are required to report certain malfunctions, deaths, and serious injuries associated with our products, which 
can result in voluntary corrective actions or agency enforcement actions. 

Under the FDA medical device reporting regulations, medical device manufacturers are required to submit 

information to the FDA when they receive a report or become aware that a device has or may have caused or 
contributed to a death or serious injury or has or may have a malfunction that would likely cause or contribute to 
death or serious injury if the malfunction were to recur. All manufacturers placing medical devices on the market in 
the EEA are legally bound to report incidents involving devices they produce or sell to the regulatory agency, or 
competent authority, in whose jurisdiction the incident occurred. Under the EU Medical Devices Directive 
(Directive 93/42/EEC), an incident is defined as any malfunction or deterioration in the characteristics and/or 
performance of a device, as well as any inadequacy in the labeling or the instructions for use which, directly or 
indirectly, might lead to or might have led to the death of a patient, or user or of other persons or to a serious 
deterioration in their state of health. 

Malfunction of our products could result in future voluntary corrective actions, such as recalls, including 
corrections, or customer notifications, or agency action, such as inspection or enforcement actions. If malfunctions 
do occur, we may be unable to correct the malfunctions adequately or prevent further malfunctions, in which case 
we may need to cease manufacture and distribution of the affected products, initiate voluntary recalls, and redesign 
the products. Regulatory authorities may also take actions against us, such as ordering recalls, imposing fines, or 
seizing the affected products. Any corrective action, whether voluntary or involuntary, will require the dedication of 
our time and capital, distract management from operating our business, and may harm our reputation and financial 
results. 

A recall of our products, either voluntarily or at the direction of the FDA, an EEA Competent Authority or 
another governmental authority, or the discovery of serious safety issues with our products, could have a 
significant adverse impact on us. 

The FDA and similar foreign governmental authorities such as the Competent Authorities of the EEA 
countries have the authority to require the recall of commercialized products in the event of material deficiencies or 
defects in design or manufacture or in the event that a product poses an unacceptable risk to health. Manufacturers 
may, under their own initiative, recall a product if any material deficiency in a device is found. A government-
mandated or voluntary recall by us or one of our distributors could occur as a result of an unacceptable risk to 
health, component failures, manufacturing errors, design or labeling defects or other deficiencies and issues. Recalls 
of any of our products would divert managerial and financial resources and have an adverse effect on our reputation, 
results of operations and financial condition, which could impair our ability to produce our products in a cost-
effective and timely manner in order to meet our customers’ demands. We may also be required to bear other costs 
or take other actions that may have a negative impact on our future sales and our ability to generate profits. 

51 

 
We may be subject to federal, state and foreign healthcare laws and regulations, and a finding of failure to 
comply with such laws and regulations could have a material adverse effect on our business. 

We are subject to healthcare fraud and abuse regulation and enforcement by federal, state and foreign 

governments, which could significantly impact our business. In the United States, the laws that may affect our 
ability to operate include, but are not limited to: 

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the federal Anti-Kickback Statute, which prohibits, among other things, persons and entities from 
knowingly and willfully soliciting, receiving, offering or paying remuneration, directly or indirectly, in 
cash or in kind, in exchange for or to induce either the referral of an individual for, or the purchase, 
lease, order or recommendation of, any good, facility, item or service for which payment may be made, 
in whole or in part, under federal healthcare programs such as Medicare and Medicaid. A person or 
entity does not need to have actual knowledge of this statute or specific intent to violate it; 

federal civil and criminal false claims laws and civil monetary penalty laws, including civil 
whistleblower or qui tam actions, that prohibit, among other things, knowingly presenting, or causing to 
be presented, claims for payment or approval to the federal government that are false or fraudulent, 
knowingly making a false statement material to an obligation to pay or transmit money or property to 
the federal government or knowingly concealing or knowingly and improperly avoiding or decreasing 
an obligation to pay or transmit money or property to the federal government; 

HIPAA, which created federal criminal laws that prohibit executing a scheme to defraud any healthcare 
benefit program or making false statements relating to healthcare matters. A person or entity does not 
need to have actual knowledge of these statutes or specific intent to violate them; 

HIPAA, as amended by the Health Information Technology for Economic and Clinical Health Act of 
2009, and their respective implementing regulations, which impose requirements on certain covered 
healthcare providers, health plans and healthcare clearinghouses as well as their business associates that 
perform services for them that involve individually identifiable health information, relating to the 
privacy, security and transmission of individually identifiable health information without appropriate 
authorization, including mandatory contractual terms as well as directly applicable privacy and security 
standards and requirements; 

the federal physician sunshine requirements under the Patient Protection and Affordable Care Act, as 
amended by the Health Care and Education Reconciliation Act, collectively, the ACA, which require 
certain manufacturers of drugs, devices, biologics, and medical supplies to report annually to the U.S. 
Department of Health and Human Services information related to payments and other transfers of value 
to physicians (defined to include doctors, dentists, optometrists, podiatrists and chiropractors) and 
teaching hospitals, and ownership and investment interests held by physicians and their immediate 
family members; 

state and foreign law equivalents of each of the above federal laws, such as state anti-kickback and false 
claims laws that may apply to items or services reimbursed by any third-party payor, including 
commercial insurers; state laws that require device companies to comply with the industry’s voluntary 
compliance guidelines and the relevant compliance guidance promulgated by the federal government, or 
otherwise restrict payments that may be made to healthcare providers and other potential referral 
sources; state laws that require device manufacturers to report information related to payments and other 
transfers of value to physicians and other healthcare providers or marketing expenditures; and state and 
foreign laws governing the privacy and security of health information in certain circumstances, many of 
which differ from each other in significant ways and often are not preempted by HIPAA. 

The scope and enforcement of each of these laws is uncertain and subject to rapid change in the current 
environment of healthcare reform, especially in light of the lack of applicable precedent and regulations. Federal and 
state enforcement bodies have recently increased their scrutiny of interactions between healthcare companies and 
healthcare providers, which has led to a number of investigations, prosecutions, convictions and settlements in the 
healthcare industry. Responding to investigations can be time-and resource-consuming and can divert management’s 
attention from the business. Additionally, as a result of these investigations, healthcare providers and entities may 
have to agree to additional onerous compliance and reporting requirements as part of a consent decree or corporate 

52 

 
integrity agreement. Any such investigation or settlement could increase our costs or otherwise have an adverse 
effect on our business. 

If our operations are found to be in violation of any of the laws described above or any other governmental 

regulations that apply to us now or in the future, we may be subject to penalties, including civil and criminal 
penalties, damages, fines, disgorgement, exclusion from governmental health care programs, and the curtailment or 
restructuring of our operations, any of which could adversely affect our ability to operate our business and our 
financial results. 

Healthcare legislative reform measures may have a material adverse effect on us. 

In March 2010, the ACA was signed into law, which included, among other things, a deductible 2.3% excise 

tax on any entity that manufactures or imports medical devices offered for sale in the United States, with limited 
exceptions, effective January 1, 2013. Subsequently, a two-year moratorium was implemented effective January 1, 
2016, such that medical device sales in 2016 and 2017 are exempt from the medical device excise tax. Unless there 
is further legislative action, the tax will be automatically reinstated for sales of medical devices on or after January 
1, 2018.  If it were to be reinstated, this excise tax would result in a significant increase in the tax burden on our 
industry, and if any efforts we undertake to offset the excise tax are unsuccessful as we begin to sell the product in 
the United States, the increased tax burden could have an adverse effect on our results of operations and cash flows. 
Other elements of the ACA, including comparative effectiveness research, an independent payment advisory board 
and payment system reforms, including shared savings pilots and other provisions, may significantly affect the 
payment for, and the availability of, healthcare services and result in fundamental changes to federal healthcare 
reimbursement programs, any of which may materially affect numerous aspects of our business. 

In addition, other legislative changes have been proposed and adopted in the United States since the ACA was 

enacted. These changes included an aggregate reduction in Medicare payments to providers of up to 2% per fiscal 
year, which went into effect on April 1, 2013 and will remain in effect through 2025 unless additional Congressional 
action is taken. On January 2, 2013, the American Taxpayer Relief Act of 2012, was signed into law which, among 
other things, further reduced Medicare payments to certain providers, including hospitals. The Medicare Access and 
CHIP Reauthorization Act of 2015, enacted on April 16, 2015 (MACRA), repealed the formula by which Medicare 
made annual payment adjustments to physicians and replaced the former formula with fixed annual updates and a 
new system of incentive payments scheduled to begin in 2019 that are based on various performance measures and 
physicians’ participation in alternative payment models such as accountable care organizations. 

There have been judicial and Congressional challenges to certain aspects of the ACA, and we expect there will 

be additional challenges and amendments to the ACA in the future. For instance, on January 20, 2017, President 
Trump signed an Executive Order stating it is his Administration’s policy to seek prompt repeal of the ACA and 
directing federal agencies with authorities and responsibilities under the ACA to waive, defer, grant exemptions 
from, or delay the implementation of any provision of the ACA that would impose a fiscal or regulatory burden on 
states, individuals, healthcare providers, health insurers, or manufacturers of pharmaceuticals or medical devices. 
Congress also could consider subsequent legislation to replace elements of the ACA that may be repealed. At this 
time, the full effect that the ACA, the Executive Order and any subsequent legislation would have on our business 
remains unclear. Any new limitations on, changes to, or uncertainty with respect to the ability of individuals to 
enroll in governmental reimbursement programs or other third-party payor insurance plans could impact demand for 
our product. 

We expect that additional state and federal healthcare reform measures will be adopted in the future, any of 

which could limit the amounts that federal and state governments will pay for healthcare products and services, 
which could result in reduced demand for our products or additional pricing pressures. 

Our future success depends on our ability to develop, receive regulatory clearance or approval for, additional 
chronic pain indications for Senza and introduce new products or product enhancements that will be accepted by 
the market in a timely manner. 

It is important to our business that we build a pipeline of product offerings for treatment of chronic pain. As 
such, our success will depend in part on our ability to expand the chronic pain indications for which Senza may be 

53 

 
used and/or develop and introduce new products. However, we may not be able to successfully develop and obtain 
regulatory clearance or approval for expanded indications or product enhancements, or new products, or these 
products may not be accepted by physicians or the payors who financially support many of the procedures 
performed with our products. 

The success of any new product offering or enhancement to an existing product will depend on a number of 

factors, including our ability to: 

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identify and anticipate physician and patient needs properly; 

develop and introduce new products or product enhancements in a timely manner; 

avoid infringing upon the intellectual property rights of third parties; 

demonstrate, if required, the safety and efficacy of new products with data from preclinical and clinical 
studies; 

obtain the necessary regulatory clearances or approvals for new products or product enhancements; 

comply fully with FDA and foreign regulations on marketing of new devices or modified products; 

provide adequate training to potential users of our products; and 

receive adequate coverage and reimbursement for procedures performed with our products. 

If we do not develop new products or product enhancements in time to meet market demand or if there is 

insufficient demand for these products or enhancements, or if our competitors introduce new products with 
functionalities that are superior to ours, our results of operations will suffer. 

Risks Related to Our Securities 

Our stock price may be volatile and as a result our stockholders may not be able to resell shares of our common 
stock at or above the price they paid and such volatility may also adversely impact the value of the 2021 Notes. 

The trading price of our common stock could be highly volatile and could be subject to wide fluctuations in 

response to various factors, some of which are beyond our control. These factors include those discussed in this 
“Risk Factors” section of this Annual Report and others such as: 

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delays or setbacks in the commercialization of Senza or the expansion of indications for which Senza is 
approved; 

announcements of new products by us or our competitors; 

achievement of expected product sales and profitability; 

manufacture, supply or distribution shortages; 

fluctuations in our expenses associated with inventory buildup or write-downs from analyzing our 
inventory for obsolesce or conformity with our product requirements; 

adverse actions taken by regulatory agencies with respect to our clinical trials, manufacturing supply 
chain or sales and marketing activities; 

our operating results; 

results from, or any delays in, clinical trial programs relating to our product candidates; 

changes or developments in laws or regulations applicable to our products; 

any adverse changes in our relationship with any manufacturers or suppliers; 

the success of our efforts to acquire or develop additional products; 

54 

 
 

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any intellectual property infringement actions in which we may become involved, including our pending 
lawsuits with Boston Scientific; 

announcements concerning our competitors or the medical device industry in general; 

actual or anticipated fluctuations in our operating results; 

FDA or other U.S. or foreign regulatory actions affecting us or our industry or other healthcare reform 
measures in the United States; 

changes in financial estimates or recommendations by securities analysts; 

trading volume of our common stock; 

trading activity in our common stock by the option counterparties to our convertible note hedge 
transactions to unwind or modify their hedge positions; 

sales of our common stock by us, our executive officers and directors or our stockholders in the future; 

general economic and market conditions and overall fluctuations in the United States equity markets; 
and 

the loss of any of our key scientific or management personnel. 

Because the 2021 Notes are convertible into shares of common stock, volatility or depressed market prices of 

our common stock could have a similar effect on the value of the 2021 Notes.  Holders who receive shares of our 
common stock upon conversion of the 2021 Notes will also be subject to the risk of volatility and depressed market 
prices of our common stock.  Similarly, the liquidity of the trading market in the 2021 Notes  and the market price 
quoted for the 2021 Notes, may be adversely affected by changes in the overall market for this type of security and 
by changes in our financial performance or prospects or in the prospects for companies in our industry generally. 

In addition, the stock markets in general, and the markets for medical device stocks in particular, have 
experienced volatility that may have been unrelated to the operating performance of the issuer. These broad market 
fluctuations may adversely affect the trading price or liquidity of our common stock and the value of the 2021 
Notes. In the past, when the market price of a stock has been volatile, holders of that stock have sometimes instituted 
securities class action litigation against the issuer. If any of our stockholders were to bring such a lawsuit against us, 
we could incur substantial costs defending the lawsuit and the attention of our management would be diverted from 
the operation of our business, which could seriously harm our financial position. Any adverse determination in 
litigation could also subject us to significant liabilities. 

Servicing our debt requires a significant amount of cash, and we may not have sufficient cash flow from our 
business to pay our substantial debt. 

Our ability to make scheduled payments of the principal of, to pay interest on or to refinance our indebtedness, 

including the 2021 Notes, depends on our future performance, which is subject to economic, financial, competitive 
and other factors beyond our control. Our business may not continue to generate cash flow from operations in the 
future sufficient to service our debt and make necessary capital expenditures. If we are unable to generate such cash 
flow, we may be required to adopt one or more alternatives, such as selling assets, restructuring debt or obtaining 
additional equity capital on terms that may be onerous or highly dilutive. Our ability to refinance our indebtedness 
will depend on the capital markets and our financial condition at such time. We may not be able to engage in any of 
these activities or engage in these activities on desirable terms, which could result in a default on our debt 
obligations. 

Recent and future regulatory actions and other events may adversely affect the value and liquidity of the 2021 
Notes. 

We expect that many investors in, and potential purchasers of, the 2021 Notes will employ, or seek to employ, 
a convertible arbitrage strategy with respect to the 2021 Notes. Investors would typically implement such a strategy 
by selling short the common stock underlying the 2021 Notes and dynamically adjusting their short position while 

55 

 
continuing to hold the 2021 Notes. Investors may also implement this type of strategy by entering into swaps on our 
common stock in lieu of or in addition to short selling the common stock. 

The SEC and other regulatory and self-regulatory authorities have implemented various rules and taken 
certain actions, and may in the future adopt additional rules and take other actions, that may impact those engaging 
in short selling activity involving equity securities (including our common stock). Such rules and actions include 
Rule 201 of SEC Regulation SHO, the adoption by the Financial Industry Regulatory Authority, Inc. and the 
national securities exchanges of a “Limit Up-Limit Down” program, the imposition of market-wide circuit breakers 
that halt trading of securities for certain periods following specific market declines, and the implementation of 
certain regulatory reforms required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 
(the Dodd-Frank Act). Any governmental or regulatory action that restricts the ability of investors in, or potential 
purchasers of, the 2021 Notes to effect short sales of our common stock, borrow our common stock or enter into 
swaps on our common stock could adversely affect the value and the liquidity of the 2021 Notes. 

If securities or industry analysts issue an adverse or misleading opinion regarding our stock, our stock price and 
trading volume could decline. 

The trading market for our common stock is influenced by the research and reports that industry or securities 

analysts publish about us or our business. If any of the analysts who cover us issues an adverse or misleading 
opinion regarding us, our business model, our intellectual property or our stock performance, or if our clinical trials 
and operating results fail to meet the expectations of analysts, our stock price would likely decline. If one or more of 
these analysts cease coverage of us or fail to publish reports on us regularly, we could lose visibility in the financial 
markets, which in turn could cause our stock price or trading volume to decline. 

We incur significantly increased costs and devote substantial management time as a result of operating as a 
public company. 

As a public company, we incur significant legal, accounting and other expenses that we did not incur as a 
private company. For example, we are subject to the reporting requirements of the Exchange Act, and are required to 
comply with the applicable requirements of the Sarbanes-Oxley Act of 2002 (Sarbanes-Oxley Act), and the Dodd-
Frank Act, as well as rules and regulations subsequently implemented by the SEC and the NYSE, including the 
establishment and maintenance of effective disclosure and financial controls and changes in corporate governance 
practices. We expect that compliance with these requirements will increase our legal and financial compliance costs 
and will make some activities more time consuming and costly. 

In addition, our management and other personnel divert attention from operational and other business matters 

to devote substantial time to these public company requirements. In particular, we incur significant expenses and 
devote substantial management effort toward ensuring compliance with the requirements of Section 404 of the 
Sarbanes-Oxley Act, which has increased now that we are no longer an emerging growth company under the 
Jumpstart Our Business Startups Act of 2012 (the JOBS Act). We continue to hire additional accounting and 
financial staff with appropriate public company experience and technical accounting knowledge. We cannot predict 
or estimate the amount of additional costs we will incur in order to remain compliant with our public company 
reporting requirements or the timing of such costs. Additional compensation costs and any future equity awards will 
increase our compensation expense, which would increase our general and administrative expense and could 
adversely affect our profitability. 

If we are unable to maintain effective internal control over financial reporting in the future, investors may lose 
confidence in the accuracy and completeness of our financial reports and the market price of our common stock 
and the value of the 2021 Notes could be adversely affected. 

As a public company, we are required to maintain internal control over financial reporting and to report any 
material weaknesses in such internal control. Section 404 of the Sarbanes-Oxley Act requires that we evaluate and 
determine the effectiveness of our internal control over financial reporting and provide a management report on 
internal control over financial reporting. The Sarbanes-Oxley Act also requires that our internal control over 
financial reporting be attested to by our independent registered public accounting firm, now that we are no longer an 
“emerging growth company,” as defined by the JOBS Act. 

56 

 
If we have a material weakness in our internal control over financial reporting, we may not detect errors on a 
timely basis and our financial statements may be materially misstated. The process of designing and implementing 
the internal control over financial reporting required to comply with this obligation is time consuming, costly and 
complicated. If we identify material weaknesses in our internal control over financial reporting, if we are unable to 
comply with the requirements of Section 404 in a timely manner, if we are unable to assert that our internal control 
over financial reporting are effective, or if our independent registered public accounting firm is unable to express an 
opinion as to the effectiveness of our internal control over financial reporting, investors may lose confidence in the 
accuracy and completeness of our financial reports and the market price of our common stock and the value of the 
2021 Notes could be adversely affected, and we could become subject to investigations by the stock exchange on 
which our securities are listed, the SEC, or other regulatory authorities, which could require additional financial and 
management resources. 

The accounting method for convertible debt securities that may be settled in cash, such as the 2021 Notes, could 
have a material effect on our reported financial results. 

In May 2008, the Financial Accounting Standards Board (FASB) issued FASB Staff Position No. APB 14-1, 

Accounting for Convertible Debt Instruments That May Be Settled in Cash Upon Conversion (Including Partial 
Cash Settlement), which has subsequently been codified as Accounting Standards Codification 470-20, Debt with 
Conversion and Other Options (ASC 470-20). Under ASC 470-20, an entity must separately account for the liability 
and equity components of the convertible debt instruments (such as the 2021 Notes) that may be settled entirely or 
partially in cash upon conversion in a manner that reflects the issuer’s economic interest cost. The effect of ASC 
470-20 on the accounting for the 2021 Notes is that the equity component is required to be included in the additional 
paid-in capital section of stockholders’ equity on our consolidated balance sheet, and the value of the equity 
component would be treated as debt discount for purposes of accounting for the debt component of the 2021 Notes. 
As a result, we are required to record a greater amount of non-cash interest expense in current periods presented as a 
result of the amortization of the discounted carrying value of the 2021 Notes to their face amount over the term of 
the 2021 Notes. We will report lower net income in our financial results because ASC 470-20 will require interest to 
include both the current period’s amortization of the debt discount and the instrument’s non-convertible interest rate, 
which could adversely affect our reported or future financial results, the trading price of our common stock and the 
value of the 2021 Notes. 

In addition, under certain circumstances, convertible debt instruments (such as the 2021 Notes) that may be 

settled entirely or partly in cash are currently accounted for utilizing the treasury stock method, the effect of which is 
that the shares issuable upon conversion of the 2021 Notes are not included in the calculation of diluted earnings per 
share except to the extent that the conversion value of the 2021 Notes exceeds their principal amount. Under the 
treasury stock method, for diluted earnings per share purposes, the transaction is accounted for as if the number of 
shares of common stock that would be necessary to settle such excess, if we elected to settle such excess in shares, 
are issued. We cannot be sure that the accounting standards in the future will continue to permit the use of the 
treasury stock method. If we are unable to use the treasury stock method in accounting for the shares issuable upon 
conversion of the 2021 Notes, then our diluted earnings per share would be adversely affected. 

If we sell shares of our common stock in future financings, stockholders may experience immediate dilution and, 
as a result, our stock price and the value of the 2021 Notes may decline. 

We may from time to time issue additional shares of common stock at a discount from the current trading 
price of our common stock. As a result, our stockholders would experience immediate dilution upon the purchase of 
any shares of our common stock sold at such discount. In addition, as opportunities present themselves, we may 
enter into financing or similar arrangements in the future, including the issuance of debt securities, preferred stock or 
common stock. If we issue common stock or securities convertible into common stock, our common stockholders 
would experience additional dilution and, as a result, our stock price and the value of the 2021 Notes may decline. 

Sales of a substantial number of shares of our common stock in the public market could cause our stock price 
and the value of the 2021 Notes to fall. 

If our existing stockholders sell, or indicate an intention to sell, substantial amounts of our common stock in 
the public market after the lapse of legal restrictions on resale, the trading price of our common stock and the value 

57 

 
of the 2021 Notes could decline. As of December 31, 2016, we had outstanding a total of approximately 28.9 million 
shares of common stock and approximately 6.0 million shares of common stock that are either subject to outstanding 
options or reserved for future issuance under our equity incentive plans will become eligible for sale in the public 
market to the extent permitted by the provisions of various vesting schedules, and Rule 144 and Rule 701 under the 
Securities Act. If these additional shares of common stock are sold, or if it is perceived that they will be sold, in the 
public market, the trading price of our common stock and the value of the 2021 Notes could decline. 

The holders of up to approximately 1.4 million shares of our outstanding common stock as of December 31, 
2016 were entitled to rights with respect to the registration of their shares under the Securities Act. Registration of 
these shares under the Securities Act would result in the shares becoming freely tradable without restriction under 
the Securities Act, except for shares purchased by affiliates. Any sales of securities by these stockholders could have 
a material adverse effect on the trading price of our common stock and could cause the value of the 2021 Notes to 
decline. 

Our principal stockholders and management own a significant percentage of our stock and will be able to exert 
significant control over matters subject to stockholder approval. 

As of December 31, 2016 our executive officers, directors, holders of 5% or more of our capital stock and 
their respective affiliates held approximately 29% of our outstanding voting stock. These stockholders will have the 
ability to influence us through this ownership position, and may be able to determine all matters requiring 
stockholder approval. For example, these stockholders may be able to control elections of directors, amendments of 
our organizational documents, or approval of any merger, sale of assets, or other major corporate transaction. This 
may prevent or discourage unsolicited acquisition proposals or offers for our common stock that our stockholders 
may feel are in their best interest. 

Provisions in our charter documents and under Delaware law could discourage a takeover that stockholders may 
consider favorable and may lead to entrenchment of management. 

Our amended and restated certificate of incorporation and amended and restated bylaws contain provisions 

that could significantly reduce the value of our shares to a potential acquirer or delay or prevent changes in control 
or changes in our management without the consent of our board of directors. The provisions in our charter 
documents include the following: 

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a classified board of directors with three-year staggered terms, which may delay the ability of 
stockholders to change the membership of a majority of our board of directors; 

no cumulative voting in the election of directors, which limits the ability of minority stockholders to 
elect director candidates; 

the exclusive right of our board of directors to elect a director to fill a vacancy created by the expansion 
of the board of directors or the resignation, death or removal of a director, which prevents stockholders 
from being able to fill vacancies on our board of directors; 

the required approval of at least 66 2/3% of the shares entitled to vote to remove a director for cause, 
and the prohibition on removal of directors without cause; 

the ability of our board of directors to authorize the issuance of shares of preferred stock and to 
determine the price and other terms of those shares, including preferences and voting rights, without 
stockholder approval, which could be used to significantly dilute the ownership of a hostile acquiror; 

the ability of our board of directors to alter our bylaws without obtaining stockholder approval; 

the required approval of at least 66 2/3% of the shares entitled to vote at an election of directors to 
adopt, amend or repeal our bylaws or repeal the provisions of our amended and restated certificate of 
incorporation regarding the election and removal of directors; 

a prohibition on stockholder action by written consent, which forces stockholder action to be taken at an 
annual or special meeting of our stockholders; 

58 

 
 

 

the requirement that a special meeting of stockholders may be called only by the board of directors, 
which may delay the ability of our stockholders to force consideration of a proposal or to take action, 
including the removal of directors; and 

advance notice procedures that stockholders must comply with in order to nominate candidates to our 
board of directors or to propose matters to be acted upon at a stockholders’ meeting, which may 
discourage or deter a potential acquiror from conducting a solicitation of proxies to elect the acquiror’s 
own slate of directors or otherwise attempting to obtain control of us. 

In addition, these provisions would apply even if we were to receive an offer that some stockholders may 

consider beneficial. 

We are also subject to the anti-takeover provisions contained in Section 203 of the Delaware General 
Corporation Law. Under Section 203, a corporation may not, in general, engage in a business combination with any 
holder of 15% or more of its capital stock unless the holder has held the stock for three years or, among other 
exceptions, the board of directors has approved the transaction.  The repurchase right under the 2021 Notes in 
connection with a fundamental change and any increase in the conversion rate in connection with a make-whole 
fundamental change could also discourage a potential acquirer. 

Claims for indemnification by our directors and officers may reduce our available funds to satisfy successful 
third-party claims against us and may reduce the amount of money available to us. 

Our amended and restated certificate of incorporation and amended and restated bylaws provide that we will 

indemnify our directors and officers to the fullest extent permitted by Delaware law. 

In addition, as permitted by Section 145 of the Delaware General Corporation Law, our amended and restated 

bylaws and our indemnification agreements that we have entered into with our directors and officers provide that: 

 

 

 

 

 

 

we will indemnify our directors and officers for serving us in those capacities or for serving other 
business enterprises at our request, to the fullest extent permitted by Delaware law. Delaware law 
provides that a corporation may indemnify such person if such person acted in good faith and in a 
manner such person reasonably believed to be in or not opposed to the best interests of the registrant 
and, with respect to any criminal proceeding, had no reasonable cause to believe such person’s conduct 
was unlawful; 

we may, in our discretion, indemnify employees and agents in those circumstances where 
indemnification is permitted by applicable law; 

we are required to advance expenses, as incurred, to our directors and officers in connection with 
defending a proceeding, except that such directors or officers shall undertake to repay such advances if 
it is ultimately determined that such person is not entitled to indemnification; 

we will not be obligated pursuant to our amended and restated bylaws to indemnify a person with 
respect to proceedings initiated by that person against us or our other indemnitees, except with respect 
to proceedings authorized by our board of directors or brought to enforce a right to indemnification; 

the rights conferred in our amended and restated bylaws are not exclusive, and we are authorized to 
enter into indemnification agreements with our directors, officers, employees and agents and to obtain 
insurance to indemnify such persons; and 

we may not retroactively amend our amended and restated bylaw provisions to reduce our 
indemnification obligations to directors, officers, employees and agents. 

We do not currently intend to pay dividends on our common stock, and, consequently, our stockholders’ ability to 
achieve a return on their investment will depend on appreciation in the price of our common stock. 

We do not currently intend to pay any cash dividends on our common stock for the foreseeable future. We 

currently intend to invest our future earnings, if any, to fund our growth. Therefore, our stockholders are not likely 

59 

 
to receive any dividends on our common stock for the foreseeable future. Since we do not intend to pay dividends, 
our stockholders’ ability to receive a return on their investment will depend on any future appreciation in the market 
value of our common stock. There is no guarantee that our common stock will appreciate or even maintain the price 
at which our stockholders have purchased it. 

ITEM 1B. UNRESOLVED STAFF COMMENTS 

None. 

ITEM 2. PROPERTIES 

Our corporate headquarters and R&D facilities are located in Redwood City, California, where we lease and 
currently occupy approximately 50,740 square feet of office and laboratory space. In December 2016, we amended 
the original lease for our corporate headquarters in order to increase the space we occupy by approximately 49,980 
square feet of office space adjacent to our corporate headquarters.  Our obligations under the amended lease for the 
new space will commence upon the earlier of the landlord completing certain improvements or when we commence 
business operations in the new space. The term of the lease for our corporate headquarters and the new adjacent 
space lasts for a period of 84 months following the commencement of the term for the additional adjacent space.  
We believe our current headquarters, together with our additional adjacent space, is sufficient for our current and 
foreseeable business needs.  We also lease office space in Switzerland and a small warehouse space in Menlo Park, 
California.  

For additional information, see Note 5. Commitments and Contingencies of Notes to Consolidated Financial 

Statements in Part II, Item 8 of this Annual Report. 

ITEM 3. LEGAL PROCEEDINGS 

On November 28, 2016, we filed a lawsuit for patent infringement against Boston Scientific Corporation and 
Boston Scientific Neuromodulation Corporation (collectively, “Boston Scientific”). The lawsuit, filed in the United 
States District Court for the Northern District of California, asserts that Boston Scientific is infringing our patents 
covering inventions relating to our Senza system and HF10 therapy. The lawsuit seeks preliminary and permanent 
injunctive relief against further infringement as well as damages and attorney’s fees. 

On December 9, 2016, Boston Scientific filed a patent infringement lawsuit alleging our manufacture, use and 

sale of the Senza system infringes certain of Boston Scientific’s patents covering SCS technology related to 
stimulation leads, rechargeable batteries and telemetry. The lawsuit, filed in the United States District Court for the 
District of Delaware, seeks unspecified damages and attorney’s fees, as well as preliminary and permanent 
injunctive relief against further infringement. 

We are and may from time to time continue to be involved in various legal proceedings of a character 
normally incident to the ordinary course of our business, including several pending European patent oppositions at 
the European Patent Office initiated by our competitors Medtronic and Boston Scientific, which we do not deem to 
be material to our business and consolidated financial statements at this stage.  

ITEM 4. MINE SAFETY DISCLOSURES 

Not applicable 

60 

 
PART II 

ITEM 5. MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND 
ISSUER PURCHASES OF EQUITY SECURITIES 

Price Range of Common Stock 

Our common stock has been publicly traded on the NYSE under the symbol “NVRO” since the initial public 
offering, or IPO, of our common stock on November 6, 2014. Prior to that time, there was no public market for our 
common stock. The following table sets forth on a per share basis, for the periods indicated, the low and high sale 
prices of our common stock as reported by the NYSE. 

Year Ended December 31, 2014 
Quarter ended December 31, 2014 (beginning 
   November 6th) 

Year Ended December 31, 2015 
Quarter ended March 31, 2015 
Quarter ended June 30, 2015 
Quarter ended September 30, 2015 
Quarter ended December 31, 2015 

Year Ended December 31, 2016 
Quarter ended March 31, 2016 
Quarter ended June 30, 2016 
Quarter ended September 30, 2016 
Quarter ended December 31, 2016 

High 

Low 

  $

39.37   $

25.00   

  $
  $
  $
  $

  $
  $
  $
  $

52.03   $
56.14   $
53.83   $
68.34   $

71.02   $
76.71   $
104.94   $
101.92   $

36.26   
45.02   
40.75   
37.09   

48.34   
59.77   
75.78   
70.41   

Holders of Record 

At February 14, 2017, there were approximately 23 stockholders of record of our common stock, and the 

closing price per share of our common stock was $93.29. Since many of our shares of common stock are held by 
brokers and other institutions on behalf of stockholders, we are unable to estimate the total number of stockholders 
represented by these record holders. 

Dividends 

We have never declared or paid cash dividends on our common stock. Because we currently intend to retain 

all future earnings to finance future growth, we do not anticipate paying any cash dividends in the near future. 

61 

 
 
 
 
   
  
      
       
  
  
   
    
   
      
       
  
  
   
    
   
      
       
  
 
Stock Performance Graph 

The following graph illustrates a comparison of the total cumulative stockholder return on our common stock 
since November 6, 2014, which is the date our common stock first began trading on the NYSE, to two indices: the 
S&P 500 Composite Index and the S&P Healthcare Equipment Index. The stockholder return shown in the graph 
below is not necessarily indicative of future performance, and we do not make or endorse any predictions as to 
future stockholder returns. This graph shall not be deemed “soliciting material” or be deemed “filed” for purposes of 
Section 18 of the Exchange Act, or otherwise subject to the liabilities under that Section, and shall not be deemed to 
be incorporated by reference into any of our filings under the Securities Act, whether made before or after the date 
hereof and irrespective of any general incorporation language in any such filing. 

November 6, 2014 December 31, 2015 December 31, 2016  
$100 investment in stock or index 
288.45  
$
Nevro Corp. (NVRO) 
110.22  
S&P 500 (GSPC) 
$
130.81   
S&P Healthcare Equipment (SPSIHE)  $

268.00 $
100.63 $
116.37 $

100.00 $
100.00 $
100.00 $

Recent Sales of Unregistered Securities 

None. 

Purchases of Equity Securities by the Issuer and Affiliated Purchasers 

None. 

62 

 
 
 
 
 
ITEM 6. SELECTED FINANCIAL DATA 

The following selected consolidated financial data is qualified in its entirety by, and should be read in 

conjunction with the consolidated financial statements and the notes thereto included in Part II, Item 8 and 
Management’s Discussion and Analysis of Financial Condition and Results of Operations included in Part II, Item 7 
of this Annual Report. The selected consolidated statements of operations data for each of the five years in the 
period ended December 31, 2016, and the consolidated balance sheet data as of December 31, 2016, 2015, 2014, 
2013 and 2012 have been derived from our audited consolidated financial statements. 

(in thousands, except per share data) 
Selected Consolidated Statements of Operations
   Data: 
Revenue 
Cost of revenue 
Gross profit 
Operating expenses: 
Research and development 
Sales, general and administrative 
Total operating expenses 
Loss from operations 

Interest and other income (expense), net 
Loss on extinguishment of debt 
Loss before income taxes 
Provision for income taxes 

Net loss 

Net loss per share attributable to common 
   stockholders, basic and diluted 
Shares used in computing basic and diluted net loss
   per common share 

2016 

2015 

2014 

2013 

2012 

Years Ended December 31, 

 $

228,504  $
75,433   
153,071   

69,606  $
28,120   
41,486   

32,573    $  23,500   $ 18,150 
7,527 
11,278      
9,473    
10,623 
21,295       14,027    

33,729   
142,423   
176,152   
(23,081)  
(5,806)  
(1,268)  
(30,155)  
1,623   
(31,778) $

21,382   
82,471   
103,853   
(62,367)  
(3,898)  
—   
(66,265)  
1,166   

15,659 
14,094 
29,753 
(19,130)
325 
— 
(18,805)
162 
(67,431) $ (30,680 )  $  (26,014 ) $ (18,967)

19,824       20,345    
29,777       18,833    
49,601       39,178    
(28,306 )     (25,151 )  
(501 )  
—    
(30,202 )     (25,652 )  
362    

(1,896 )    
—      

478      

(1.12) $

(2.54) $

(6.94 )  $ 

(29.84 ) $ (38.59)

 $

 $

   28,485,003    26,581,890    4,440,663       876,932     494,066  

2016 

Years Ended December 31, 
2014 

2013 

2015 

2012 

(in thousands, except per share data) 
Selected Consolidated Balance Sheet Data: 
Cash and cash equivalents 
Short-term investments 
Working capital 
Total assets 
Long-term debt 
Total stockholders' equity (deficit) 

  $ 41,406    $ 87,036    $ 25,287     $  12,409     $
5,618 
  $ 234,951    $ 106,634    $ 151,521     $  44,123     $ 24,997 
  $ 378,093    $ 246,242    $ 190,327     $  66,870     $ 43,572 
  $ 430,583    $ 291,183    $ 202,496     $  75,411     $ 49,111 
  $ 138,140    $ 19,740    $ 19,511     $ 
— 
  $ 249,034    $ 234,592    $ 172,070     $  (85,790 )   $ (61,794)

—     $

ITEM 7. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS 
OF OPERATIONS 

This Annual Report includes “forward-looking statements” within the meaning of the federal securities laws, 

particularly statements referencing our expectations relating to the productivity of our sales force, revenues, deferred 
revenues, cost of revenues, operating expenses, stock-based compensation and provision for income taxes; the 
growth of our customer base and customer demand for our products; the sufficiency of our cash balances and cash 
flows; the impact of recent changes in accounting standards; market risk sensitive instruments; contractual 
obligations; and assumptions underlying any of the foregoing. In some cases, forward-looking statements can be 
identified by the use of terminology such as “may,” “will,” “expects,” “intends,” “plans,” “anticipates,” “estimates,” 
“potential,” or “continue,” or the negative thereof, or other comparable terminology. Although we believe that the 
expectations reflected in the forward-looking statements contained herein are reasonable, these expectations or any 

63 

 
 
  
 
  
 
 
   
  
 
 
  
 
  
   
   
      
    
 
  
  
  
   
   
      
    
 
  
  
  
  
  
  
  
  
 
  
 
 
  
 
 
 
 
 
     
    
 
 
  
 
   
     
     
       
      
 
 
of the forward-looking statements could prove to be incorrect, and actual results could differ materially from those 
projected or assumed in the forward-looking statements. Our future financial condition and results of operations, as 
well as any forward-looking statements, are subject to risks and uncertainties, including but not limited to the factors 
set forth in this Annual Report under Part I, Item 1A. Risk Factors. All forward-looking statements and reasons why 
results may differ included in this Annual Report are made as of the date of the filing of this Annual Report, and we 
assume no obligation to update any such forward-looking statements or reasons why actual results may differ. 

The following discussion should be read in conjunction with our consolidated financial statements and notes 

thereto appearing in Part II, Item 8 of this Annual Report. 

Overview 

We are a global medical device company focused on providing innovative products that improve the quality of 

life of patients suffering from chronic pain.  We have developed and commercialized the Senza spinal cord 
stimulation (SCS) system, an evidence-based neuromodulation platform for the treatment of chronic pain. Our 
proprietary paresthesia-free HF10 therapy, delivered by our Senza system, was demonstrated in our SENZA-RCT 
study to be superior to traditional SCS therapy with Senza being nearly twice as successful in treating back pain and 
1.5 times as successful in treating leg pain when compared to traditional SCS therapy.  Comparatively, traditional 
SCS therapy has limited efficacy in treating back pain and is used primarily for treating leg pain, limiting its market 
adoption. Our SENZA-RCT study, along with our European studies, represents what we believe is the most robust 
body of clinical evidence for any SCS therapy. We believe the superiority of HF10 therapy over traditional SCS 
therapies will allow us to capitalize on and expand the approximately $1.6 to $1.8 billion existing global SCS 
market by treating back pain in addition to leg and pain without paresthesia. 

We launched Senza commercially in the United States in May 2015, after receiving a label from the FDA 
supporting the superiority of our HF10 therapy over traditional SCS.  The Senza system has been commercially 
available in certain European markets since November 2010 and in Australia since August 2011. We have 
experienced consistent significant revenue growth in the United States since commercial launch and, effective 
January 1, 2016, receive transitional pass-through payment under the Medicare hospital outpatient prospective 
payment system. In addition, on the basis of our strong clinical evidence, Senza is covered by each of the top 10 
national insurance providers. In early 2017, we commenced a controlled commercial launch of our surgical lead, 
marketed as the Surpass surgical lead, which we believe will provide us access to an additional approximately 30% 
of the U.S. SCS market that we previously did not address. The tables below sets forth our revenue from U.S. and 
international sales the past two years on a quarterly basis and total revenue for each of the past three years. 

Q1 2015      Q2 2015  

  Q3 2015  

  Q4 2015  

  Q1 2016  

  Q2 2016       Q3 2016  

  Q4 2016  

(in millions) 

Revenue from U.S. sales 
Revenue from international sales   
$ 
Total sales revenue 

4.5    $ 19.8    $ 29.5    $ 40.6      $  47.2    $ 56.0 
N/A      $
9.7       
14.5 
9.7      $ 11.4    $ 15.4    $ 33.1    $ 41.7    $ 55.4      $  60.9    $ 70.5  

0.1    $
11.3     

14.8         13.7     

13.3     

12.2     

10.9     

Total revenue 

$

32.6     $

69.6      $ 

228.5  

2014 

2015 
(in millions) 

2016 

Since inception, we have financed our operations primarily through equity and debt financings and borrowings 
under a debt facility. Our accumulated deficit as of December 31, 2016 was $221.2 million. A significant amount of 
our capital resources has been used to support the development of Senza and our HF10 therapy and we have also 
made a significant investment building our U.S. commercial infrastructure and sales force to support our 
commercialization efforts in the United States. We intend to continue to make significant investments in our U.S. 
commercial infrastructure, as well as in R&D to develop Senza to treat other chronic pain indications, including 
conducting clinical trials to support our future regulatory submissions. In order to further enhance our R&D efforts, 
pursue product expansion opportunities or acquire a new business or products that are complementary to our 
business, we may choose to raise additional funds, which may include future equity and debt financings. 

64 

 
  
  
  
 
 
  
 
  
  
  
 
  
 
We rely on third-party suppliers for all of the components of Senza and for the assembly of the system. Many 

of these suppliers are currently single-source suppliers. During 2015 and 2016, we entered into and/or amended 
several supply agreements in an effort to reinforce our supply chain.  We are also required to maintain high levels of 
inventory, and, as a result, we are subject to the risk of inventory obsolescence and expiration, which may lead to 
inventory impairment charges. In particular, we have substantially increased our levels of inventory in order to meet 
our estimated demand in the United States and, as a result, incur significant expenditures associated with such 
increases in our inventory. Additionally, as compared to direct manufacturers, our dependence on third-party 
manufacturers exposes us to greater lead times increasing our risk of inventory obsolesce. 

Our IPO closed in November 2014 at which time we received cash proceeds of approximately $131.6 million, 

net of underwriting discounts and commissions and offering costs paid by us. In June 2015, we completed an 
underwritten public offering of our common stock and we received cash proceeds of approximately $118.4 million, 
net of underwriting discounts and commissions and offering costs paid by us.  In June 2016, we issued $172.5 
million aggregate principal amount of 1.75% convertible senior notes due 2021, or the 2021 Notes, in a registered 
underwritten public offering for total net proceeds, after deducting transaction costs, of approximately $166.2 
million.   

In November 2016, we filed a lawsuit for patent infringement against Boston Scientific, asserting that Boston 

Scientific is infringing our patents covering inventions related to our HF10 therapy and the Senza system.  In 
December 2016, Boston Scientific, filed its own lawsuit alleging that we infringed Boston Scientific’s patents 
covering technology related to stimulation leads, batteries and telemetry units.  Each of the lawsuits seek 
preliminary and permanent injunctive relief against further infringement as well as damages and attorney fees. We 
believe pursuing our lawsuit and defending ourselves against Boston Scientific’s lawsuit will require significant 
cash resources over the immediate and near long term.  

Important Factors Affecting our Results of Operations 

We believe that the following factors have impacted and we expect will continue to impact our results of 

operations. 

Importance of Physician Awareness and Acceptance of Senza 

We continue to invest in programs to educate physicians who treat chronic pain about the advantages of 
Senza. This requires significant commitment by our marketing team and sales organization, and can vary depending 
upon the physician’s practice specialization, personal preferences and geographic location. Further, we are 
competing with well-established companies in our industry that have strong existing relationships with many of 
these physicians. Educating physicians about the advantages of Senza, and influencing these physicians to use Senza 
to treat chronic pain, is required to grow our revenue. 

Reimbursement and Coverage Decisions by Third-Party Payors 

Healthcare providers in the United States generally rely on third-party payors, principally federal Medicare, 

state Medicaid and private health insurance plans, to cover and reimburse all or part of the cost of Senza and the 
related implant procedure for patients. The revenue we are able to generate from sales of Senza depends in large part 
on the availability of reimbursement from such payors. While we currently have a favorable reimbursement decision 
from federal Medicare, decisions of coverage and reimbursement for Senza and the related implant procedure from 
private health insurance providers can vary. In general, these decisions require that such payors perform analyses to 
determine if the procedure is medically necessary and if our technology is covered under their existing coverage 
policy. These payors may deny reimbursement if they determine that the device or procedure was not used in 
accordance with the payor’s coverage policy, is subject to individual plan benefit limitations or is investigational 
and/or experimental.  A significant component of our commercial efforts include working with private payors to 
ensure positive coverage and reimbursement decisions for Senza. While favorable reimbursement decisions from 
federal Medicare and certain commercial payors, such as Aetna, Cigna, Humana and Kaiser, have facilitated our 
increase in revenue to date, certain regional Blue Cross Blue Shield plans, have denied coverage for Senza on the 
basis that high-frequency neuromodulation is investigational and/or experimental. We continue to engage in efforts 
to convince such payors of the advantages of HF10 therapy and while we have overturned some 

65 

 
investigational/experimental designations, such as Cigna, Blue Cross Blue Shield Highmark and Blue Cross Blue 
Shield of Alabama, there can be no assurances that we are successful in overturning negative coverage decisions by 
private health insurance plans.  A significant number of negative coverage and reimbursement decisions by private 
insurers may impair our ability or delay our ability to grow our revenue. 

Inventory Buildup and Supply Chain Management 

Our Senza product consists of a substantial number of individual components and, in order to market and sell 

Senza effectively, we must maintain high levels of inventory. In particular, as we continue with our commercial 
launch of Senza in the United States and continue to add additional suppliers to fortify our supply chain, we are 
substantially increasing our levels of inventory. As a result, we are incurring significant uses of cash associated with 
the increases in our inventory, which will include satisfying certain minimum purchase obligations, as demand for 
Senza in the United States is developing. There may also be times in which we determine that our inventory does not 
meet our product requirements, as was the case for the years ended December 31, 2016 and 2015, wherein we 
recorded a write down of inventory of $3.7 million and $2.1 million, respectively. Further, the manufacturing 
process for Senza requires lengthy lead times, during which components may become obsolete. We may also over- 
or under-estimate the amount needed of a given component, in which case we may expend extra resources or be 
constrained in the amount of end product that we can produce. These factors subject us to the risk of inventory 
obsolescence and expiration, which may lead to inventory impairment charges. 

Investment in Research and Clinical Trials 

We intend to continue investing in R&D to expand into new indications and chronic pain conditions for 
Senza, as well as develop product enhancements to improve outcomes and enhance the physician and patient 
experience. For example, we recently commenced a controlled commercial launch of Surpass, our surgical lead 
product, and we are currently investing in product improvements to Senza, including enhanced MRI capabilities and 
a next generation IPG. While R&D and clinical testing are time consuming and costly, we believe expanding into 
new indications, implementing product improvements and continuing to demonstrate HF10 efficacy, safety and cost 
effectiveness through clinical data, each are critical to increasing the adoption of HF10 therapy. 

Significant Investment in U.S. Sales Organization 

We are continuing to make significant investments in building our U.S. commercial infrastructure and 
recruiting and training our U.S. sales force. This is a lengthy process that requires recruiting appropriate sales 
representatives, establishing a commercial infrastructure in the United States and training our sales representatives, 
and will require significant investment. Following initial training for Senza, our sales representatives typically 
require lead time in the field to grow their network of accounts and produce sales results. Successfully recruiting and 
training a sufficient number of productive sales representatives is required to achieve growth at the rate we expect.  
As we gain U.S. market share, we expect that growth rates will moderate. 

Access to Hospital Facilities 

In the United States, in order for physicians to use Senza, the hospital facilities where these physicians treat 

patients typically will require us to enter into purchasing contracts. This process can be lengthy and time-consuming 
and requires extensive negotiations and management time. In Europe, we may be required to engage in a contract 
bidding process in order to sell Senza, which processes are only open at certain periods of time, and we may not be 
successful in the bidding process. 

We Do Not Expect Our Revenue Growth Rate in International Markets to Continue at Historic Rates 

Our revenue from international markets has increased from $18.2 million for the year ended December 31, 

2012 to $55.2 million for the year ended December 31, 2016. Revenue increased as a result of our sales of Senza in 
Europe and Australia, however, we do not expect to continue this rate of revenue growth in these international 
markets given our existing penetration in these markets. Despite our growth in international markets, international 
revenue was negatively impacted by the appreciation of the U.S. dollar. Due to governmental reimbursements 

66 

 
constraints in the European SCS market limiting the number of annual SCS implants and our current penetration in 
these markets, we expect to grow less rapidly in the future than we have in the past in this market. 

Critical Accounting Policies, Significant Judgments and Use of Estimates 

Our management’s discussion and analysis of financial condition and results of operations are based upon our 

consolidated financial statements, which have been prepared in accordance with accounting principles generally 
accepted in the United States of America, or U.S. GAAP. The preparation of these consolidated financial statements 
requires us to make estimates and judgments that affect the reported amounts of assets, liabilities, revenues and 
expenses. On an ongoing basis, we evaluate our critical accounting policies and estimates. We base our estimates on 
historical experience and on various other assumptions that we believe to be reasonable in the circumstances, the 
results of which form the basis for making judgments about the carrying values of assets and liabilities that are not 
readily apparent from other sources. Actual results may differ from these estimates under different assumptions and 
conditions. We believe that the estimates, judgments and assumptions involved in the accounting for revenue 
recognition, inventory, stock-based compensation, income taxes and allowance for doubtful accounts have the 
greatest potential impact on our consolidated financial statements, so we consider these to be our critical accounting 
policies. We discuss below the critical accounting estimates associated with these policies. Historically, our 
estimates, judgments, and assumptions relative to our critical accounting policies have not differed materially from 
actual results. Our significant accounting policies are more fully described in Note 2, Summary of Significant 
Accounting Policies, of Notes to Consolidated Financial Statements in Part II, Item 8 of this Annual Report. 

Revenue 

We recognize revenue when all of the following criteria are met: 

 

 

 

 

persuasive evidence of an arrangement exists; 

the sales price is fixed or determinable; 

collection of the relevant receivable is reasonably assured at the time of sale; and 

delivery has occurred or services have been rendered. 

For a majority of sales, where our sales representative delivers our product at the point of implantation at 
hospitals or medical facilities, we recognize revenue upon completion of the procedure and authorization, which 
represents satisfaction of the required revenue recognition criteria. For the remaining sales, which are sent from our 
distribution centers directly to hospitals and medical facilities, as well as distributor sales where product is ordered 
in advance of an implantation procedure and a valid purchase order has been received, we recognize revenue at the 
time of shipment of the product, which represents the point in time when the customer has taken ownership and 
assumed the risk of loss and the required revenue recognition criteria are satisfied. Such customers are obligated to 
pay within specified terms regardless of when or if they ever sell or use the products. We do not offer rights of 
return or price protection and we have no post-delivery obligations. We periodically provide incentive offers to 
customers.  Product revenue is recorded net of such incentive offers. 

Warranty Obligations 

We have a limited one- to five-year warranty to most customers and we warrant that our products will operate 
substantially in conformity with product specifications. We record an estimate for the provision for warranty claims 
in cost of revenue when the related revenues are recognized.  This estimate is based on historical and anticipated 
rates of warranty claims, the cost per claim and the number of units sold.  We regularly assess the adequacy of our 
recorded warranty liabilities and adjusts the amounts as necessary. 

Inventory Valuation 

We contract with third parties for the manufacturing and packaging of all of the components of Senza. We 

plan the manufacture of our systems based on estimates of market demand. The nature of our business requires that 
we maintain sufficient inventory on hand to meet the requirements of our customers. Inventories are stated at the 

67 

 
lower of cost or market value. Cost is determined using actual cost on a first-in, first-out basis. Market value is 
determined as the lower of replacement cost or net realizable value. 

We regularly review inventory quantities in consideration of actual loss experiences, projected future demand 

and remaining shelf life to record a provision for excess and obsolete inventory when appropriate. Inventory write 
downs are recorded for excess and obsolete inventory. We periodically assesses the recoverability of all inventories 
to determine whether write downs for impairment are required. We evaluate projected future demand as compared to 
remaining shelf life and other obsolescence and excess criteria in assessing the recoverability of our inventory. In 
determining the adequacy of reserves, we analyze the following, among other things: 

 

 

 

 

 

 

 

 

Current inventory quantities on hand; 

Product acceptance in the marketplace; 

Customer demand; 

Historical sales; 

Forecast sales; 

Product obsolescence; 

Technological innovations; and 

Character of the inventory as a distributed item, finished manufactured item or system components. 

Any inventory write-downs are recorded in cost of goods sold within the statements of operations during the 

period in which such write-downs are determined necessary by management. 

Stock-Based Compensation 

Stock-based compensation costs related to stock options granted to employees are measured at the date of 
grant based on the estimated fair value of the award, net of estimated forfeitures. We estimate the grant date fair 
value, and the resulting stock-based compensation expense, using the Black-Scholes option-pricing model.  The fair 
value is recognized on a straight-line basis over the requisite service period of the stock option award, which is 
generally the vesting term of four years, with the exception of performance based stock option awards, whose fair 
value is recognized as expenses when it is determined that achieving the performance metrics are probable. 

The Black-Scholes option-pricing model requires the use of highly subjective assumptions which determine 

the fair value of stock-based awards. The assumptions used in our option-pricing model represent management’s 
best estimates. These estimates are complex, involve a number of variables, uncertainties and assumptions and the 
application of management’s judgment, so that they are inherently subjective. If factors change and different 
assumptions are used, our stock-based compensation expense could be materially different in the future. These 
assumptions are estimated as follows: 

Risk-Free Interest Rate. We base the risk-free interest rate used in the Black-Scholes valuation model on the 
implied yield available on U.S. Treasury zero-coupon issues with an equivalent remaining term of the options for 
each option group. 

Expected Term. The expected term represents the period that our stock-based awards are expected to be 
outstanding. Because of the limitations on the sale or transfer or our common stock as a privately held company, we 
do not believe our historical exercise pattern is indicative of the pattern we will experience as a publicly traded 
company. We have consequently used the Staff Accounting Bulletin, or SAB, 110, simplified method to calculate 
the expected term, which is the average of the contractual term and vesting period. Starting in late 2016, we have 
started to utilize our historical data for the calculation of expected term. 

Volatility. We determine the price volatility factor based on the historical volatilities of our peer group as we 

did not have a sufficient trading history for our common stock. Industry peers consist of several public companies in 
the medical device technology industry with comparable characteristics including enterprise value, risk profiles and 

68 

 
position within the industry. We intend to continue to consistently apply this process using the same or similar 
public companies until a sufficient amount of historical information regarding the volatility of our own common 
stock share price becomes available, or unless circumstances change such that the identified companies are no 
longer similar to us, in which case, more suitable companies whose share prices are publicly available would be 
utilized in the calculation.  Starting in late 2016, we have started to incorporate our historical stock trading volatility 
with those of our peer group for the calculation of volatility. 

Dividend Yield. The expected dividend assumption is based on our current expectations about our anticipated 

dividend policy. We currently do not expect to issue any dividends. 

In addition to assumptions used in the Black-Scholes option-pricing model, we must also estimate a forfeiture 

rate to calculate the stock-based compensation for our awards. We will continue to use judgment in evaluating the 
assumptions related to our stock-based compensation on a prospective basis. As we continue to accumulate 
additional data, we may have refinements to our estimates, which could materially impact our future stock-based 
compensation expense. 

In 2015, we began issuing restricted stock units, or RSUs.  We account for stock-based compensation for the 
RSUs at their fair value, based on the closing market price of our common stock on the grant date.  These costs are 
recognized on a straight-line basis over the requisite service period, which is generally the vesting term of four 
years, with the exception of performance based RSUs, which are recognized as expenses when it is determined that 
achieving the performance metrics are probable. 

We estimate the fair value of the rights to purchase shares by employees under our Employee Stock Purchase 
Plan using the Black-Scholes option pricing formula. Our Employee Stock Purchase Plan provides for consecutive 
six-month offering periods and we use our own historical volatility data in the valuation. 

Income Tax 

We recognize deferred income taxes for temporary differences between the basis of assets and liabilities for 
financial statement and income tax purposes. We periodically evaluate the positive and negative evidence bearing 
upon realizability of our deferred tax assets. Based upon the weight of available evidence, which includes our 
historical operating performance, reported cumulative net losses since inception and difficulty in accurately 
forecasting our future results, we maintained a full valuation allowance on the net deferred tax assets as of 
December 31, 2016 and 2015. We intend to maintain a full valuation allowance on the federal, state and foreign 
deferred tax assets until sufficient positive evidence exists to support reversal of the valuation allowance. 

As of December 31, 2016, we had federal and state net operating loss (NOL) carryforwards of $224.7 million 

and $77.3 million, respectively, available to offset future taxable income, due to prior period losses, which if not 
utilized will begin to expire in 2026 for federal purposes and will begin to expire in 2017 for state purposes. We also 
have federal research tax credit carryforwards that will begin to expire in 2026. Realization of these NOL and 
research tax credit carryforwards depends on future income, and there is a risk that our existing carryforwards could 
expire unused and be unavailable to reduce future income tax liabilities, which could materially and adversely affect 
our results of operations. 

In addition, under Section 382 of the Internal Revenue Code of 1986, as amended, or the Code, our ability to 
utilize NOL carryforwards or other tax attributes such as research tax credits, in any taxable year may be limited if 
we experience, or have experienced, an “ownership change.” A Section 382 “ownership change” generally occurs if 
one or more stockholders or groups of stockholders, who own at least 5% of our stock, increase their ownership by 
more than 50 percentage points over their lowest ownership percentage within a rolling three-year period. Similar 
rules may apply under state tax laws. 

No deferred tax assets have been recognized on our balance sheet related to our NOLs and tax credits, as they 

are fully reserved by a valuation allowance. As a result of our June 2015 underwritten public offering, we have 
experienced a Section 382 “ownership change.”  We currently estimate this “ownership change” will not inhibit our 
ability to utilize our NOLs.  We may in the future experience another Section 382 “ownership change.” If so, or if 

69 

 
we do not generate sufficient taxable income, we may not be able to utilize a material portion of our NOLs and tax 
credits even if we achieve profitability. If we are limited in our ability to use our NOLs and tax credits in future 
years in which we have taxable income, we will pay more taxes than if we were able to fully utilize our NOLs and 
tax credits. This could materially and adversely affect our results of operations. 

We record unrecognized tax benefits as liabilities and adjust these liabilities when our judgment changes as a 

result of the evaluation of new information not previously available. Because of the complexity of some of these 
uncertainties, the ultimate resolution may result in a payment that is materially different from our current estimate of 
the unrecognized tax benefit liabilities. These differences will be reflected as increases or decreases to income tax 
expense in the period in which new information is available. Our policy is to recognize interest and penalties related 
to income taxes as a component of income tax expense. No interest or penalties related to income taxes have been 
recognized in the statements of operations and comprehensive loss in 2016 and 2015. 

Allowance for Doubtful Accounts 

We must make estimates of the collectability of accounts receivable. In doing so, we analyze historical bad 
debt trends, customer credit worthiness, current economic trends and changes in customer payment patterns when 
evaluating the adequacy of the allowance for doubtful accounts. Our accounts receivable balance was $52.8 million, 
net of allowance of $1.0 million, as of December 31, 2016 and $22.5 million, net of allowance of $0.1 million, as of 
December 31, 2015. 

Components of Results of Operations 

Revenue 

Our revenue is generated from sales to two types of customers: hospitals and outpatient medical facilities 
served through a direct sales force and third-party distributors. Sales to hospitals and medical facilities represent the 
majority of our revenue. Product sales to hospitals and medical facilities are billed to, and paid by, the hospitals as 
part of their normal payment processes, with payment received by us in the form of an electronic transfer, check or 
credit card payment. Product sales to distributors are billed to and paid by the distributors as part of their normal 
payment processes, with payment received by us in the form of an electronic transfer. 

Revenue from sales of Senza fluctuate based on the selling price of the system, as the sales price of a system 
varies geographically, and based on the mix of sales by geography. In addition, our revenue may fluctuate based on 
the ratio of trials to permanent implants. Our revenue from international sales can also be significantly impacted by 
fluctuations in foreign currency exchange rates, as our sales are denominated in the local currency in the countries in 
which we sell our products. 

We expect our revenue to fluctuate from quarter to quarter due to a variety of factors, including seasonality, as 

we have historically experienced lower sales in the summer months and around holidays, and the impact of the 
buying patterns and implant volumes of our hospitals and medical facilities, and third-party distributors. In addition, 
in the second quarter of 2015, we commenced commercial sales of Senza in the United States and recorded revenue 
of approximately $173.3 million and $24.4 million for the years ended December 31, 2016 and 2015, respectively, 
for sales in the United States.  We anticipate that our total revenue will increase as we continue our 
commercialization in the United States. 

Cost of Revenue 

We utilize contract manufactures for the production of Senza. Cost of revenue consists primarily of 
acquisition costs of the components of Senza, allocated manufacturing overhead, royalty payments, scrap and 
inventory obsolescence, as well as distribution-related expenses, such as logistics and shipping costs, net of costs 
charged to customers. 

We calculate gross margin as revenue less cost of revenue divided by revenue. Our gross margin has been and 
will continue to be affected by a variety of factors, primarily by our costs to have our products manufactured for us, 
the ratio of trials to permanent implants, the period of time between a trial and the related permanent implant and, to 

70 

 
a lesser extent, the percentage of products we sell to distributors as compared to those sold directly to hospitals and 
medical facilities as our gross margin is typically higher on products we sell directly as compared to products we sell 
through distributors. While costs are primarily incurred in U.S. dollars, international revenue may be impacted by 
the appreciation or depreciation of the U.S. dollar, which may impact our overall gross margin. We expect our gross 
margin to be positively affected over time to the extent we are successful in reducing manufacturing costs as our 
sales volume increases. However, our gross margin may fluctuate from period to period. 

Operating Expenses 

Our operating expenses consist of R&D expense and sales, general and administrative, or SG&A, expense. 

Personnel costs are the most significant component of operating expenses and consist of salaries, bonus incentives, 
benefits, stock-based compensation and sales commissions. We expect operating expenses to increase in absolute 
dollars, as we continue to invest to grow our business. 

Research and Development (R&D). R&D costs are expensed as incurred. R&D expense consists primarily of 

personnel costs, including salary, employee benefits and stock-based compensation expenses for our R&D 
employees. R&D expense also includes costs associated with product design efforts, development prototypes, 
testing, clinical trial programs and regulatory activities, contractors and consultants, equipment and software to 
support our development, facilities and information technology. We expect R&D expense to increase in absolute 
dollars as we continue to develop product enhancements to Senza and develop our HF10 therapy to treat other 
chronic pain indications, including conducting additional clinical studies. Our R&D expenses may fluctuate from 
period to period due to the timing and extent of our R&D and clinical trial expenses. 

Sales, General and Administrative. SG&A expense consists primarily of personnel costs, including salary, 
employee benefits and stock-based compensation expenses for our sales and marketing personnel, including sales 
commissions, and for administrative personnel that support our general operations, such as information technology, 
executive management, financial accounting, customer services and human resources personnel. We expense 
commissions at the time of the sale. SG&A expense also includes costs attributable to marketing, as well as travel, 
intellectual property and other legal fees, financial audit fees, insurance, fees for other consulting services, 
depreciation and facilities. 

In the last two years, we significantly increased the size of our sales presence internationally and increased 

marketing spending to generate sales opportunities. Additionally, we have made substantial investments in our U.S. 
commercial infrastructure to support our commercialization efforts in the United States. We expect SG&A expenses 
to continue to significantly increase as we build up our sales and marketing personnel to support commercialization 
of Senza in the United States, continue to increase the size of our sales and marketing organizations and increase our 
international presence and develop and assist our channel partners. 

For the year ended December 31, 2016, our administrative expenses increased compared to the same period in 

the prior year. We expect our administrative expenses will continue to increase as we increase our headcount and 
expand our facility and information technology to support our growing operations. Additionally, we anticipate 
increased expenses related to audit, legal, regulatory and tax-related services associated with maintaining 
compliance with exchange listing and U.S. Securities and Exchange Commission requirements, including 
compliance under the Sarbanes-Oxley Act of 2002, or the Sarbanes-Oxley Act, as a large accelerated filer, director 
and officer insurance premiums and investor relations costs associated with being a growing public company. Our 
SG&A expense may fluctuate from period to period due to the seasonality of our revenue and the timing and extent 
of our SG&A expense. 

Interest Income and Interest Expense 

Interest income consists primarily of interest income earned on our investments and interest expense consists 

of interest paid on our outstanding debt and the amortization of debt discount and debt issuance costs. 

71 

 
Other Income (Expense), Net 

Other income (expense), net consists primarily of foreign currency transaction gains and losses and the gains 

and losses from the remeasurement of foreign-denominated balances to the U.S. dollar. 

Provision for Income Taxes 

The provision for income taxes consists primarily of income taxes in foreign jurisdictions in which we 

conduct business as well as states where we have determined we have state nexus. We maintain a full valuation 
allowance for our deferred tax assets including NOL carryforwards and R&D credits and other tax credits. 

Allowance for Doubtful Accounts 

We make estimates as to the overall collectability of accounts receivable and provide an allowance for 
accounts receivable considered uncollectible. We specifically analyze accounts receivable based on historical bad 
debt experience, customer concentrations, customer credit-worthiness, the age of the receivable, current economic 
trends, and changes in customer payment terms when evaluating the adequacy of the allowance for doubtful 
accounts. We record the adjustment in general and administrative expense. 

Recent Accounting Pronouncements 

For recent accounting pronouncements, see Note 2, Summary of Significant Accounting Policies, of Notes to 

Consolidated Financial Statements in Part II, Item 8 of this Annual Report. 

Comparison of the Years Ended December 31, 2016 and 2015 

Revenue, Cost of Revenue, Gross Profit and Gross Margin 

(in thousands) 
Revenue 
Cost of revenue 
Gross profit 
Gross margin 

  Years Ended December 31, 

2016 

2015 

      Change 

  $ 228,504   $
75,433    
  $ 153,071   $
67% 

69,606     $  158,898  
28,120       
47,313  
41,486     $  111,585  
60% 

7% 

Revenue. Revenue increased to $228.5 million in 2016 from $69.6 million in 2015, an increase of 

$158.9 million, or 228%, due to increased sales of the Senza system in the United States, which began in May 2015 
upon receiving FDA approval of our PMA for Senza, and continued adoption of the Senza system in international 
markets where it had historically been sold. Further, the increase in sales of the Senza system was driven in part by 
our expanded sales force in the United States in 2016. 

Cost of Revenue, Gross Profit and Gross Margin. Cost of revenue increased to $75.4 million in 2016 from 
$28.1 million in 2015, an increase of $47.3 million, or 168%.  This increase was primarily due to a $40.0 million 
increase in the costs of manufactured product components as sales volumes increased, as well as a $1.3 million 
increase in inventory-related charges. Gross profit increased to $153.1 million in 2016 from $41.5 million in 2015, 
an increase of $111.6 million, or 269%.  Gross profit as a percentage of revenue, or gross margin, increased to 67% 
in 2016 compared to 60% in 2015.  The increase was partly attributed to lower manufacturing costs as a percentage 
of sales.  Additionally, while costs were primarily incurred in U.S. dollars, international revenue was negatively 
impacted by the appreciation of the U.S. dollar, which negatively impacted the overall gross margin for the period. 

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Operating Expenses 

(in thousands) 
Operating expenses: 

Years Ended December 31, 

2016 

2015 

  Amount 

% of 
Total 
Revenue  

  Amount 

% of 
Total 

Revenue      

Change 
Amount

Research and development 
Sales, general and administrative 
Total operating expenses 

  $ 33,729     
    142,423     
  $ 176,152     

15% 
62% 
77% 

    $ 21,382        31% 

    $ 12,347 
59,952 
    $ 103,853        149%      $ 72,299  

82,471        118%       

Research and Development (R&D) Expenses. R&D expenses increased to $33.7 million in 2016 from $21.4 

million in 2015, an increase of $12.3 million, or 58%.  The increase was primarily due to an increase in clinical and 
development expenses of $5.8 million, headcount and related personnel and consulting costs of $4.5 million and 
other healthcare professional related expenses of $1.3 million. 

Sales, General and Administrative (SG&A) Expenses. SG&A expenses increased to $142.4 million in 2016 

from $82.5 million in 2015, an increase of $60.0 million, or 73%.  This increase was primarily due to an increase in 
personnel costs of $47.9 million in relation to an increase in headcount for SG&A personnel in support of our 
continued U.S. commercial launch, increased legal and other professional services costs of $3.2 million, including 
an increase of $1.3 million related to legal expenses incurred in connection with the Boston Scientific litigations, 
increased travel, training and associated supply costs of $2.8 million, increased marketing expenses of $1.8 million, 
additional facilities-related costs of $1.7 million and increased computer hardware and software expenses of $1.0 
million. 

Interest Income, Interest Expense, Other Income (Expense), Net and Provision for Income Taxes 

(in thousands) 
Interest income 
Interest expense 
Other income (expense), net 
Loss on extinguishment of debt 
Provision for income taxes 

  Years Ended December 31,         

2016 

2015 

      Change 

  $

1,685    $
(6,394)   
(1,097)   
(1,268)   
1,623     

575     $ 
(2,732 )     
(1,741 )     
—       
1,166       

1,110  
(3,662 )
644  
(1,268 )
457   

Interest Income. Interest income increased to $1.7 million in 2016 from $0.6 million in 2015, primarily as a 

result of the increase in average investment balances. 

Interest Expense. Interest expense increased to $6.4 million from $2.7 million in 2015, primarily as a result of 

the amortization of debt discount and debt issuance costs related to the issuance of the 2021 Notes. 

Other Income (Expense), Net. Other income (expense), net was primarily comprised of foreign currency 

transaction gains and losses and the gains and losses from the remeasurement of foreign-denominated balances. 
Related to these two items, in 2016, we recorded a net loss of $0.9 million, compared to 2015 when we recorded a 
net loss of $1.6 million.  Our remeasurement gains and losses are affected by changes in the foreign currency 
translation rates of the countries in which we conduct business. 

Loss on Extinguishment of Debt. We paid in full the outstanding obligation under our credit facility in June 

2016.  The difference between the total payment to the lenders under the credit facility and the net carrying amount 
of the obligation recorded on our balance sheet was recorded as a loss on extinguishment of debt. 

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Income Tax Expense. Income tax expense was $1.6 million in 2016 and $1.2 million in 2015. Our income tax 

expense is associated primarily with foreign and state income taxes. We continue to generate tax losses for U.S. 
federal and state tax purposes and have NOL carryforwards creating a deferred tax asset. We have a full valuation 
allowance for our deferred tax assets. The change in income tax expense was primarily due to changes in foreign 
income taxes on profits realized by our foreign subsidiaries. 

Comparison of the Years Ended December 31, 2015 and 2014 

Revenue, Cost of Revenue, Gross Profit and Gross Margin 

(in thousands) 
Revenue 
Cost of revenue 
Gross profit 
Gross margin 

  Years Ended December 31, 

2015 

2014 

      Change 

  $

  $

69,606   $
28,120    
41,486   $
60% 

32,573     $ 
11,278       
21,295     $ 
65% 

37,033  
16,842  
20,191  

(5)% 

Revenue. Revenue increased to $69.6 million in 2015 from $32.6 million in 2014, an increase of 
$37.0 million, or 114%, due to sales of the Senza system in the United States, which began in May 2015 upon 
receiving FDA approval of our PMA for Senza, and continued adoption of the Senza system in international markets 
where it had historically been sold. We expanded our sales force in the United States in 2015 to support our 
anticipated revenue growth. 

Cost of Revenue, Gross Profit and Gross Margin. Cost of revenue increased to $28.1 million in 2015 from 
$11.3 million in 2014, an increase of $16.8 million, or 149%.  This increase was primarily due to a $12.7 million 
increase in the acquisition costs of manufactured product components as sales volumes increased, as well as a $2.0 
million increase in inventory-related charges. Gross profit increased to $41.5 million in 2015 from $21.3 million in 
2014, an increase of $20.2 million, or 95%.  Gross profit as a percentage of revenue, or gross margin, decreased to 
60% in 2015 compared to 65% in 2014.  The decrease was partly attributed to the costs incurred in association with 
ramping our operational infrastructure in response to the product launch in the United States, as well as the $2.0 
million increase in the write down of inventory in 2015.  Additionally, while costs were primarily incurred in U.S. 
dollars, international revenue was negatively impacted by the appreciation of the U.S. dollar, which negatively 
impacted the overall gross margin for the period. 

Operating Expenses 

(in thousands) 
Operating expenses: 

Research and development 
Sales, general and administrative 
Total operating expenses 

Years Ended December 31, 

2015 

2014 

  Amount 

% of 
Total 
Revenue  

  Amount 

% of 
Total 

Revenue      

Change 
Amount

31% 

  $ 21,382     

1,558 
52,694 
  $ 103,853      149%      $ 49,601        152%      $ 54,252  

    $ 19,824        61% 
29,777        91% 

82,471      118%       

    $

Research and Development (R&D) Expenses. R&D expenses increased to $21.4 million in 2015 from $19.8 

million in 2014, an increase of $1.6 million, or 8%.  The increase was primarily due to an increase in headcount and 
related personnel and consulting costs of $3.1 million, offset by a decrease in clinical and development expenses of 
$1.4 million associated with our preclinical and regulatory costs in preparation for our June 2014 PMA submission, 
as well as a decrease in costs related to the reduction of R&D participation in the manufacturing process 
development of $0.8 million. 

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Sales, General and Administrative (SG&A) Expenses. SG&A expenses increased to $82.5 million in 2015 
from $29.8 million in 2014, an increase of $52.7 million, or 177%.  This increase was primarily due to an increase in 
personnel costs of $35.6 million in relation to an increase in headcount for SG&A personnel in support of our U.S. 
commercial launch, increased travel, training, marketing and associated supply costs of $9.5 million, increased legal 
and other professional services costs associated with being a public company of $4.2 million, additional facilities-
related costs of $2.3 million and increased computer hardware and software expenses of $0.6 million. 

Interest Income, Interest Expense, Other Income (Expense), Net and Provision for Income Taxes 

(in thousands) 
Interest income 
Interest expense 
Other income (expense), net 
Provision for income taxes 

  Years Ended December 31,         

2015 

2014 

      Change 

  $

575    $
(2,732)   
(1,741)   
1,166     

141     $ 
(157 )     
(1,880 )     
478       

434  
(2,575 )
139  
688   

Interest Income. Interest income increased to $0.6 million in 2015 from $0.1 million in 2014, primarily as a 

result of the increase in average investment balances. 

Interest Expense. Interest expense increased to $2.7 million in 2015 from $0.2 million in 2014, primarily as a 

result of debt outstanding during 2015 as a result of borrowing under our credit facility in December 2014. 

Other Income (Expense), Net. Other income (expense), net was primarily comprised of foreign currency 

transaction gains and losses and the gains and losses from the remeasurement of foreign-denominated balances. 
Related to these two items, in 2015, we recorded a net loss of $1.6 million, compared to the corresponding period in 
prior year in which we recorded a net loss of $1.7 million.  Our remeasurement gains and losses are affected by 
changes in the foreign currency translation rates of the countries in which we conduct business. 

Income Tax Expense. Income tax expense was $1.2 million in 2015 and $0.5 million in 2014. Our income tax 
expense during these periods is associated primarily with foreign income taxes. We continue to generate tax losses 
for U.S. federal and state tax purposes and have NOL carryforwards creating a deferred tax asset. We have a full 
valuation allowance for our deferred tax assets. The change in income tax expense was due to changes in foreign 
income taxes on profits realized by our foreign subsidiaries. 

Liquidity, Capital Resources and Plan of Operations 

Since our inception, we have financed our operations through private placements of preferred stock, the 

issuance of common stock in our IPO in November 2014 and our underwritten public offering in June 2015, 
borrowing under our credit facility, which we have subsequently repaid, and the issuance of convertible senior notes 
due 2021 in June 2016. At December 31, 2016, we had cash, cash equivalents and short-term investments of $276.4 
million.  Based on our current operating plan, we expect that our cash and cash equivalents on hand, together with 
the anticipated funds from the collection of our receivables, will be sufficient to fund our operations through at least 
the next 12 months. 

In June 2016, we paid the outstanding principal and repayment fees under our credit facility with Capital 
Royalty Partners and certain of its affiliates and terminated the credit facility.  As of December 31, 2016, we do not 
have a credit facility in place. 

We expect to incur substantial expenditures in the foreseeable future in connection with the expansion of our 

U.S. commercial infrastructure and sales force in connection with commercializing Senza in the United States. In 
addition, we intend to continue to make investments in the development of Senza and HF10 therapy for the 
treatment of other chronic pain conditions, including ongoing R&D programs and conducting clinical trials. Further, 
we expect to expand significant cash resources pursuing and defending our ongoing lawsuits with Boston Scientific. 

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In order to further enhance our R&D efforts, pursue product expansion opportunities or acquire a new business or 
products that are complementary to our business, we may choose to raise additional funds. 

We may continue to seek funds through equity or debt financings, or through other sources of financing. 
Adequate additional funding may not be available to us on acceptable terms or at all. Our failure to raise capital in 
the future could have a negative impact on our financial condition and our ability to pursue our business strategies. 
Should we choose to raise additional capital, the requirements will depend on many factors, including: 

 

 

 

 

 

 

 

 

 

the costs of commercialization activities related to commercializing Senza in the United States and 
elsewhere, including product sales, marketing, manufacturing and distribution; 

the cost of filing, prosecuting, defending and enforcing any patent claims and other intellectual property 
rights, including, in particular, the costs of enforcing our patent rights in the action we filed against 
Boston Scientific and in defending against Boston Scientific’s action against us; 

the R&D activities we intend to undertake in order to expand the chronic pain indications and product 
enhancements that we intend to pursue; 

whether or not we pursue acquisitions or investments in businesses, products or technologies that are 
complementary to our current business; 

the degree and rate of market acceptance of Senza in the United States and elsewhere; 

changes or fluctuations in our inventory supply needs and forecasts of our supply needs; 

our need to implement additional infrastructure and internal systems; 

our ability to hire additional personnel to support our operations as a public company; and 

the emergence of competing technologies or other adverse market developments. 

Our success depends, in part, upon our ability to establish a competitive position in the neuromodulation 
market by securing broad market acceptance of our HF10 therapy and Senza for the treatment of chronic pain 
conditions. Any product we develop that achieves regulatory clearance or approval will have to compete for market 
acceptance and market share. We face significant competition in the United States and internationally, which we 
believe will intensify as we continue to commercialize in the United States.  For example, our major competitors, 
Medtronic, Boston Scientific and Abbott Laboratories (through its recent acquisition of St. Jude Medical), each have 
approved neuromodulation systems in at least the United States, Europe and Australia and have been established for 
several years. In addition to these major competitors, we may also face competition from other emerging 
competitors and smaller companies with active neuromodulation system development programs that may emerge in 
the future. 

If we are unable to raise, or have access, to sufficient funds when needed, we may be required to delay, 

reduce, or terminate some or all of our commercial development plans. 

The following table sets forth the primary sources and uses of cash for each of the periods presented below: 

(in thousands) 
Net cash provided by (used in) 

Years Ended December 31, 
2015 

2014 

2016 

Operating activities 
Investing activities 
Financing activities 
Effect of exchange rate on cash flows 

(604)   
Net increase (decrease) in cash and cash equivalents    $ (45,630)  $

  $ (58,503)  $ (100,430 )   $  (31,148 )
39,658        (108,055 )
    (131,687)   
    145,164      122,827        152,081  
—  
61,749     $  12,878   

(306 )     

Cash Used in Operating Activities. Net cash used in operating activities was $58.5 million, $100.4 million and 

$31.1 million for the years ended December 31, 2016, 2015 and 2014, respectively, primarily due to the net losses 

76 

 
 
  
 
  
  
 
   
     
  
   
     
       
  
   
     
       
  
   
 
during the periods of $31.8 million, $67.4 million and $30.7 million, respectively. The cash used in operating 
activities for the year ended December 31, 2016 was affected by a net increase of $6.6 million in accounts payable 
and accrued liabilities, as well as non-cash stock based compensation expense of $15.8 million, a write down of 
inventories of $4.1 million and non-cash interest expense of $3.7 million.  These changes are offset by increases in 
our accounts receivable of $32.2 million and inventory balances of $27.0 million. The cash used in operating 
activities for the year ended December 31, 2015 was affected by changes in operating assets and liabilities, including 
an increase of $25.0 million in accounts payable and accrued liabilities, non-cash stock based compensation expense 
of $7.3 million and a write down of inventories of $2.8 million, offset by increases in our inventory balances of 
$49.4 million, accounts receivable of $16.2 million and prepaid expenses and other assets of $2.6 million. The cash 
used in operating activities for the year ended December 31, 2014 was affected by changes in operating assets and 
liabilities, including an increase of $3.0 million in accounts payable and accrued liabilities and non-cash stock based 
compensation expense of $2.0 million, offset by an increase in our prepaid expenses and other current assets of 
$1.3 million, and an increase in our inventory balances by $5.5 million. 

Cash Used in Investing Activities. Investing activities consisted primarily of changes in investment balances, 

including purchases and maturities of short-term investments, and purchases of property equipment. For the year 
ended December 31, 2016, we had net purchases of investments of $128.4 million and purchases in property and 
equipment of $3.4 million.  For the year ended December 31, 2015, we had net proceeds from maturity of 
investments of $45.3 million, offset by purchases in property and equipment of $5.0 million.  For the year ended 
December 31, 2014 we had net investment purchases of $107.4 million. 

Cash Provided by Financing Activities. Cash provided by financing activities was $145.2 million for the year 

ended December 31, 2016.  The majority of this cash was provided by the issuance of $172.5 million in aggregate 
principal amount of the 2021 Notes.  Additionally, we received proceeds of $10.3 million from the issuance of 
common stock to employees. The cash received from these activities was partially offset by a net expense of $12.0 
million incurred in connection with the purchase of convertible note hedge and warrant transactions, which included 
the $45.1 million purchase of convertible note hedges and proceeds of $33.1 million related to the sale of warrants. 
The increase in cash provided by financing activities was partially offset by $6.2 million of issuance costs incurred 
in connection with the 2021 Notes and $19.5 million used in relation to the repayment of the credit facility. Cash 
provided by financing activities was $122.8 million for the year ended December 31, 2015, primarily due to the cash 
received from the issuance of common stock in our underwritten public offering in June 2015 totaling $118.4 
million and cash received from the issuance of common stock to employees of $4.4 million. Cash provided by 
financing activities for the year ended December 31, 2014 was $152.1 million, primarily from the $131.6 million in 
net proceeds received in the IPO, as well as borrowing under our note payable of $19.5 million, which consisted of 
borrowings of $20.0 million, and closing fees of $0.5 million. 

Contractual Obligations and Commitments 

We have lease obligations consisting of operating leases for our principal offices, which expire as set forth 
below, and for our warehouse space that expire in 2017, as well as for office space in Switzerland that expire in 
2017. 

In March 2015, we entered into a lease agreement for approximately 50,000 square feet of office space located 

in Redwood City, California for a period beginning in June 2015 and ending in May 2022, with initial annual 
payments of approximately $2.0 million, increasing to $2.4 million annually in the final year of the lease term.  In 
December 2016, we entered into an amendment for an additional approximately 50,000 square feet of office space 
adjacent to the premises under the original lease, or the Expansion Premises, with initial annual payments of $1.2 
million, increasing to $2.9 million in the final year of the amended lease term.  The lease for the Expansion Premises 
commences on the earlier of the following dates, or the Commencement Date: (i) the date we commence business 
operations in the Expansion Premises or (ii) the date upon which the landlord for the Expansion Premises 
substantially completes certain improvements to, and permitting for, the Expansion Premises. The amendment also 
extends the lease term for the original premises to terminate on the same date as the amended lease, which is the last 
day of the calendar month following the date that is 84 months after the Commencement Date.  Under the 
amendment, if we are unable to move into the Expansion Premises before the Scheduled Delivery Date, as defined 
in the amendment, we may terminate the lease for the Expansion Premises.  See Note 5, Commitments and 
Contingencies, of Notes to Consolidated Financial Statements for additional information. 

77 

 
In March 2015, we extended our warehouse lease through February 2017 under which we are obligated to pay 

approximately $0.3 million in lease payments over the remaining term of the lease.  

We have entered into supply agreements with certain of our suppliers that required certain minimum annual 

purchase agreements.  As of December 31, 2016, we had minimum annual purchase commitments $25.0 million due 
in 2017 and $5.5 million due in each of 2018, 2019, 2020 and 2021. 

Our contractual obligations related to the 2021 Notes are payments of $3.0 million due each year from 2017 
through 2020 and $174.0 million due in 2021. These amounts represent principal and interest cash payments over 
the term of the 2021 Notes. 

Excluding the terms under the amendment for the Expansion Premises, which is subject to certain cancellation 

clauses, the following table summarizes our contractual obligations as of December 31, 2016 (in thousands): 

Payment date by period 

Total 

Less than 1 
year 

  1 to 3 years  
(in thousands) 

   4 to 5 years       

More than 5 
years 

Notes payable, including contractual interest    $ 186,085    $
12,518     
Lease obligations 
47,175     
Purchase obligations 
  $ 245,778    $

Total 

3,019    $
2,167     
25,013     
30,199    $

6,038     $ 177,028      $
4,705       
4,435       
11,081       
11,081       
21,554     $ 192,814      $

— 
1,211 
— 
1,211  

Off-Balance Sheet Arrangements 

Through December 31, 2016, we did not have any relationships with unconsolidated organizations or financial 

partnerships, such as structured finance or special purpose entities that would have been established for the purpose 
of facilitating off-balance sheet arrangements or other contractually narrow or limited purposes. For information 
regarding indemnification obligations, refer to Note 5, Commitments and Contingencies, of Notes to the 
Consolidated Financial Statements within Part II, Item 8 of this Annual Report. 

Segment Information 

We have one primary business activity and operate as one reportable segment. 

ITEM 7A. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK 

Interest Rate Risk 

We are exposed to limited market risk related to fluctuations in interest rates and market prices. Our primary 
exposure to market risk is interest rate sensitivity, which is affected by changes in the general level of U.S. interest 
rates. The primary objective of our investment activities is to preserve our capital to fund our operations. 

We also seek to maximize income from our investments without assuming significant risk. To achieve our 

objectives, we maintain a portfolio of cash equivalents and investments in a variety of securities of high credit 
quality. As of December 31, 2016, we had cash and cash equivalents of $41.4 million, consisting of cash and money 
market funds, and short-term investments of $235.0 million, consisting of commercial paper and corporate notes. 
We maintained investments in money market funds that were not federally insured during the year ended 
December 31, 2016 and held cash in foreign banks of approximately $3.3 million and $5.2 million at December 31, 
2016 and 2015 that was not federally insured. A portion of our investments may be subject to interest rate risk and 
could fall in value if market interest rates increase. However, because our investments are primarily short-term in 
duration, we believe that our exposure to interest rate risk is not significant. We do not enter into investments for 
trading or speculative purposes and have not used any derivative financial instruments to manage our interest rate 
risk exposure. A hypothetical 1% change in interest rates during any of the periods presented would not have had a 
material impact on our consolidated financial statements. 

78 

 
 
  
 
 
  
 
 
 
 
 
  
  
 
   
   
 
Foreign Currency Exchange Risk 

To date, a portion of our revenue and operating expenses are incurred outside the United States and are 
denominated in foreign currencies and are subject to fluctuations due to changes in foreign currency exchange rates, 
particularly changes in the Australian dollar, the Euro and the United Kingdom pound sterling. Additionally, 
fluctuations in foreign currency exchange rates may cause us to recognize transaction gains and losses in our 
statement of operations. As a component of other income (expense), we recognized net foreign currency transaction 
losses of $0.9 million, $1.6 million and $1.7 million for the years ended December 31, 2016, 2015 and 2014, 
respectively. A hypothetical 10% favorable or unfavorable change in the weighted average foreign exchange rates 
for the year ended December 31, 2016 would have affected the Company’s net loss by approximately 8%. To date, 
we have not engaged in any foreign currency hedging transactions. As our international operations grow, we will 
continue to reassess our approach to managing the risks relating to fluctuations in currency rates. 

We do not believe that inflation and change in prices had a significant impact on our results of operations for 

any periods presented in our consolidated financial statements. 

See Note 2, Summary of Significant Accounting Policies, of Notes to Consolidated Financial Statements for 

further information on foreign currency translation. 

Market Risk and Market Interest Risk 

In June 2016, we issued $172.5 million aggregate principal amount of 1.75% convertible senior notes due 
2021.  The fair value of our convertible senior notes is subject to interest rate risk, market risk and other factors due 
to the convertible feature.  The fair value of the convertible senior notes will generally increase as our common 
stock price increases and will generally decrease as our common stock price declines in value.  The interest and 
market value changes affect the fiar value of our convertible senior notes but do not impact our financial position, 
cash flows or results of operations due to the fixed nature of the debt obligation.  Additionally, we carry the 
convertible senior notes at face value less unamortized discount on our balance sheet, and we present the fair value 
for required disclosure purposes only. 

See Note 6, Long-term Debt, of Notes to Consolidated Financial Statements for further information. 

ITEM 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA 

The following consolidated financial statements, and the related notes thereto, of Nevro Corp. and the Report 

of the Company’s Independent Registered Public Accounting Firm are filed as a part of this Annual Report. 

79 

 
 
Report of Independent Registered Public Accounting Firm 

To the Board of Directors and Stockholders of Nevro Corp.  

In our opinion, the accompanying consolidated balance sheets and the related consolidated statements of operations 
and comprehensive loss, of convertible preferred stock, redeemable convertible preferred stock and stockholders’ 
equity (deficit) and of cash flows present fairly, in all material respects, the financial position of Nevro Corp. and its 
subsidiaries at December 31, 2016 and December 31, 2015, and the results of their operations and their cash flows 
for each of the three years in the period ended December 31, 2016 in conformity with accounting principles 
generally accepted in the United States of America. Also in our opinion, the Company maintained, in all material 
respects, effective internal control over financial reporting as of December 31, 2016, based on criteria established in 
Internal Control - Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the 
Treadway Commission (COSO). The Company's management is responsible for these financial statements, for 
maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal 
control over financial reporting, included in Management’s Report on Internal Control Over Financial Reporting 
appearing under Item 9A. Our responsibility is to express opinions on these financial statements and on the 
Company's internal control over financial reporting based on our integrated audits. We conducted our audits in 
accordance with the standards of the Public Company Accounting Oversight Board (United States).  Those 
standards require that we plan and perform the audits to obtain reasonable assurance about whether the financial 
statements are free of material misstatement and whether effective internal control over financial reporting was 
maintained in all material respects.  Our audits of the financial statements included examining, on a test basis, 
evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles 
used and significant estimates made by management, and evaluating the overall financial statement presentation.  
Our audit of internal control over financial reporting included obtaining an understanding of internal control over 
financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and 
operating effectiveness of internal control based on the assessed risk.  Our audits also included performing such 
other procedures as we considered necessary in the circumstances. We believe that our audits provide a reasonable 
basis for our opinions. 

A company’s internal control over financial reporting is a process designed to provide reasonable assurance 
regarding the reliability of financial reporting and the preparation of financial statements for external purposes in 
accordance with generally accepted accounting principles.  A company’s internal control over financial reporting 
includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, 
accurately and fairly reflect the transactions and dispositions of the assets of the company; (ii) provide reasonable 
assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance 
with generally accepted accounting principles, and that receipts and expenditures of the company are being made 
only in accordance with authorizations of management and directors of the company; and (iii) provide reasonable 
assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s 
assets that could have a material effect on the financial statements. 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  
Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become 
inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may 
deteriorate. 

/s/ PricewaterhouseCoopers LLP 

San Jose, California 
February 23, 2017 

80 

 
 
 
 
 
 
 
Nevro Corp. 
Consolidated Balance Sheets 
(in thousands, except share and per share data) 

Assets 
Current assets 

Cash and cash equivalents 
Short-term investments 
Accounts receivable, net of allowance for doubtful accounts of $1,008 
   and $122 at December 31, 2016 and 2015, respectively 
Inventories 
Prepaid expenses and other current assets 

Total current assets 

Property and equipment, net 
Other assets 
Restricted cash 

Total assets 

Liabilities and stockholders’ equity 
Current liabilities 

Accounts payable 
Accrued liabilities 
Other current liabilities 

Total current liabilities 

Long-term debt 
Other long-term liabilities 

Total liabilities 

Commitments and contingencies (Note 5) 
Stockholders’ equity 

Preferred stock, $0.001 par value, 10,000,000 shares authorized at 
   December 31, 2016 and 2015, respectively; zero shares issued and 
   outstanding at December 31, 2016 and 2015, respectively 
Common stock, $0.001 par value, 290,000,000 shares authorized at 
   December 31, 2016 and 2015, respectively; 28,886,862 and 28,143,573 
   shares issued and outstanding at December 31, 2016 and 2015, 
   respectively 
Additional paid-in capital 
Accumulated other comprehensive loss 
Accumulated deficit 

Total stockholders’ equity 
Total liabilities and stockholders’ equity 

December 31, 
2016 

     December 31, 

2015 

  $

  $

  $

41,406      $ 
234,951        

52,818        
85,221        
5,895        
420,291        
7,132        
2,354        
806        
430,583      $ 

16,162      $ 
26,028        
8        
42,198        
138,140        
1,211        
181,549        

87,036 
106,634 

22,522 
62,430 
4,009 
282,631 
5,794 
1,852 
906 
291,183 

21,887 
14,381 
121 
36,389 
19,740 
462 
56,591 

—        

— 

29        
470,869        
(678 )      
(221,186 )      
249,034        
430,583      $ 

28 
424,147 
(175)
(189,408)
234,592 
291,183  

  $

The accompanying notes are an integral part of these consolidated financial statements. 

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Nevro Corp. 
Consolidated Statements of Operations and Comprehensive Loss 
(in thousands, except share and per share data) 

  $

Revenue 
Cost of revenue 
Gross profit 
Operating expenses 
Research and development 
Sales, general and administrative 
Total operating expenses 
Loss from operations 

Interest income 
Interest expense 
Other income (expense), net 
Loss on extinguishment of debt 
Loss before income taxes 
Provision for income taxes 

Net loss 

Years Ended December 31, 
2015 

2016 
228,504    $
75,433     
153,071     

33,729     
142,423     
176,152     
(23,081)    
1,685     
(6,394)    
(1,097)    
(1,268)    
(30,155)    
1,623     
(31,778)    

69,606      $ 
28,120        
41,486        

21,382        
82,471        
103,853        
(62,367 )      
575        
(2,732 )      
(1,741 )      
—        
(66,265 )      
1,166        
(67,431 )      

2014 

32,573 
11,278 
21,295 

19,824 
29,777 
49,601 
(28,306)
141 
(157)
(1,880)
— 
(30,202)
478 
(30,680)

Accretion of redeemable convertible preferred stock to redemption
   value 
Net loss attributable to common stockholders 
Other comprehensive loss: 

Changes in foreign currency translation adjustment 
Changes in unrealized losses on short-term investments, net 

Net change in other comprehensive loss 

Comprehensive Loss 
Net loss per share, basic and diluted 
Weighted average number of common shares used to 
   compute basic and diluted net loss per share 

—     
(31,778)    

—        
(67,431 )      

(147)
(30,827)

(163)    
(340)    
(503)    
(32,281)   $
(1.12)   $

(178 )      
(74 )      
(252 )      
(67,683 )    $ 
(2.54 )    $ 

(147)
196 
49 
(30,778)
(6.94)

  $
  $

    28,485,003      26,581,890        

4,440,663  

The accompanying notes are an integral part of these consolidated financial statements. 

82 

 
 
  
 
 
  
 
 
 
     
 
   
   
   
     
        
 
   
   
   
   
   
   
   
   
   
   
   
   
   
   
     
        
 
   
   
   
 
 
 
Nevro Corp. 
Consolidated Statements of Convertible Preferred Stock, Redeemable Convertible Preferred Stock and Stockholders’ Equity (Deficit) 
(in thousands, except share data) 

Balances at December 31, 2013 
Accretion of redeemable convertible preferred stock 
   issuance costs 
Conversion of preferred stock to common stock 
Issuance of common stock upon initial public offering, net 
   of issuance costs 
Issuance of common stock in connection with license 
   agreement 
Exercise of common stock options 
Vesting of early exercised stock options 
Stock based compensation 
Net loss 
Other comprehensive income 
Balances at December 31, 2014 
Issuance of common stock upon underwritten public 
   offering, net of issuance costs 
Exercise of common stock options 
Issuance of common stock under employee stock purchase 
   plan 
Vesting of early exercised stock options 
Stock based compensation 
Net loss 
Other comprehensive loss 
Balances at December 31, 2015 
Conversion feature of convertible senior notes due 2021, 
   net of allocated costs 
Purchase of bond hedges 
Sales of warrants 
Exercise of common stock options 
Issuance of common stock upon release of restricted stock 
   units 
Issuance of common stock under employee stock purchase 
   plan 
Vesting of early exercised stock options 
Stock based compensation 
Tax benefit from stock option deductions 
Net loss 
Other comprehensive loss 
Balances at December 31, 2016 

  Series A Convertible 

Preferred Stock 

Series B and C 
Redeemable Convertible  
Preferred Stock 

Shares 

     Amount   
   5,437,826   $ 47,217      9,770,222     $ 106,018 

    Amount     

Shares 

Common Stock 

    Additional     
    Paid-In 
      Amount      Capital 

Shares 
1,120,416      $ 

1   $

5,331  $ 

Accumulated 
   Accumulated     Other Comprehensive    Stockholders'   
    Equity (Deficit)  
Income (Loss) 
    Deficit 
(85,790)

(91,150)  $ 

28   $ 

Total 

—    
   (5,437,826)   

—      

—        
(47,217)     (9,770,222)      (106,165 ) 15,208,048        

—       

147 

—      
—    
15      153,367    

(147)    
—      

—     
—     

(147)
153,382 

—    

—      

—       

—  

8,050,000        

8      131,609    

—      

—     

131,617 

—    
—    
—    
—    
—    
—    
—    

—    
—    

—    
—    
—    
—    
—    
—    

—    
—    
—    
—    

—      
—      
—      
—      
—      
—      
—      

—      
—      

—      
—      
—      
—      
—      
—      

—      
—      
—      
—      

—       
—       
—       
—       
—       
—       
—       

—       
—       

—       
—       
—       
—       
—       
—       

—       
—       
—       
—       

—    

—      

—       

20,833        
—  
466,194        
—  
—        
—  
—        
—  
—        
—  
—  
—        
—   24,865,491        

523    
—      
963    
1     
154    
—      
1,998    
—      
—    
—      
—      
—    
25      293,945    

—      
—      
—      
—      
(30,680)    
—      
(121,977 )    

—  
—  

2,470,587        
774,337        

3      118,436    
2,958    

—      

—      
—      

—  
33,158        
—  
—        
—  
—        
—  
—        
—        
—  
—   28,143,573        

—      
1,430    
—      
53    
—      
7,325    
—      
—    
—    
—      
28      424,147    

—      
—      
—      
(67,431)    
—      
(189,408 )    

—  
—  
—  
—  

—  

—        
—        
—        
669,337        

—      
—      
—      
1     

31,767    
(45,092)   
33,120    
6,807    

1,384        

—      

—    

—      
—      
—      
—      

—      

—    
—    
—    
—    
—    
—    
—    

—      
—      
—      
—      
—      
—      
—      

—       
—       
—       
—       
—       
—       
—       

72,568        
—  
—        
—  
—        
—  
—        
—  
—        
—  
—  
—        
—   28,886,862      $ 

3,499    
—      
47    
—      
15,760    
—      
814    
—      
—    
—      
—      
—    
29   $ 470,869  $ 

—      
—      
—      
—      
(31,778)    
—      
(221,186 )  $ 

—     
—     
—     
—     
—     
49     
77     

—     
—     

—     
—     
—     
—     
(252)    
(175)    

—     
—     
—     
—     

—     

—     
—     
—     
—     
—     
(503)    
(678)  $ 

523 
964 
154 
1,998 
(30,680)
49 
172,070 

118,439 
2,958 

1,430 
53 
7,325 
(67,431)
(252)
234,592 

31,767 
(45,092)
33,120 
6,808 

—  

3,499 
47 
15,760 
814 
(31,778)
(503)
249,034   

The accompanying notes are an integral part of these consolidated financial statements. 

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Nevro Corp. 
Consolidated Statements of Cash Flows 
(in thousands) 

Cash flows from operating activities 
Net loss 
Adjustments to reconcile net loss to net cash used in operating activities 

Depreciation and amortization 
Stock-based compensation expense 
Accretion of discount on short-term investments 
Non-cash research and development expense 
Non-cash loss on extinguishment of debt 
Payment of original issue discount 
Provision for doubtful accounts 
Write-down of inventory 
Loss on disposal of equipment 
Non-cash interest expense 
Unrealized gains (losses) on foreign currency transactions 
Changes in operating assets and liabilities 

Accounts receivable 
Inventories 
Prepaid expenses and other current assets 
Other assets 
Accounts payable 
Accrued liabilities 
Other long-term liabilities 

Net cash used in operating activities 

Cash flows from investing activities 
Purchases of short-term investments 
Proceeds from maturity of short-term investments 
Changes in restricted cash 
Purchases of property and equipment 

Net cash provided by (used in) investing activities 

Cash flows from financing activities 
Proceeds from issuance of notes payable 
Proceeds from issuance of common stock in public offering, net 
Proceeds from issuance of convertible notes 
Convertible notes initial issuance discount and debt issuance costs 
Proceeds from issuance of warrants 
Purchase of convertible note hedges 
Repayment of debt 
Proceeds from issuance of common stock to employees 

Net cash provided by financing activities 
Effect of exchange rate changes on cash and cash equivalents 

Net increase (decrease) in cash and cash equivalents 

Cash and cash equivalents 
Cash and cash equivalents at beginning of period 
Cash and cash equivalents at end of period 

Supplemental disclosures of cash flow information 
Cash paid for income taxes 
Cash paid for interest 

Significant non-cash transactions 
Purchases of property and equipment in accounts payable 
Vesting of early-exercised stock options 

Years Ended December 31, 
2015 

2014 

2016 

  $

(31,778)   $

(67,431 )    $ 

(30,680)

1,717     
15,760     
(231)    
—     
1,156     
(1,500)    
909     
4,056     
287     
3,681     
1,854     

(32,181)    
(27,031)    
(1,997)    
(505)    
(5,586)    
12,136     
750     
(58,503)    

(372,309)    
243,890     
100     
(3,368)    
(131,687)    

—     
—     
172,500     
(6,171)    
33,120     
(45,092)    
(19,500)    
10,307     
145,164     
(604)    
(45,630)    

614        
7,325        
(458 )      
—        
—        
—        
90        
2,767        
—        
231        
(682 )      

(16,233 )      
(49,407 )      
(1,197 )      
(1,432 )      
17,051        
7,987        
345        
(100,430 )      

(190,000 )      
235,272        
(606 )      
(5,008 )      
39,658        

—        
118,439        
—        
—        
—        
—        
—        
4,388        
122,827        
(306 )      
61,749        

96 
1,998 
82 
523 
— 
— 
(172)
754 
— 
11 
— 

167 
(5,487)
(1,337)
(204)
1,283 
1,763 
55 
(31,148)

(159,265)
51,835 
— 
(625)
(108,055)

19,500 
131,617 
— 
— 
— 
— 
— 
964 
152,081 
— 
12,878 

  $

  $
  $

  $
  $

87,036     
41,406    $

25,287        
87,036      $ 

12,409 
25,287 

492    $
2,469    $

670      $ 
2,332      $ 

725    $
47    $

752      $ 
53      $ 

243 
— 

— 
154  

The accompanying notes are an integral part of these consolidated financial statements. 

84 

 
 
  
  
 
  
  
    
    
 
   
     
        
 
   
     
        
 
   
   
   
   
   
   
   
   
   
   
   
   
     
        
 
   
   
   
   
   
   
   
   
   
     
        
 
   
   
   
   
   
   
     
        
 
   
   
   
   
   
   
   
   
   
   
   
   
     
        
 
   
   
     
        
 
   
     
        
 
 
Nevro Corp. 
Notes to Consolidated Financial Statements 

1. Formation and Business of the Company 

We were incorporated in Minnesota on March 10, 2006 to manufacture and market innovative active 

implantable medical devices for the treatment of neurological disorders initially focusing on the treatment of chronic 
pain. Subsequently, we were reincorporated in Delaware on October 4, 2006 and relocated to California. 

Since inception, the Company has incurred net losses and negative cash flows from operations. During the 

year ended December 31, 2016, the Company incurred a net loss of $31.8 million and used $58.5 million of cash in 
operations. At December 31, 2016, the Company had an accumulated deficit of $221.2 million and does not expect 
to experience positive cash flows in the immediate future. The Company has financed operations to date primarily 
through private placements of equity securities, borrowings under a debt agreement, the issuance of common stock 
in its November 2014 initial public offering, and its June 2015 underwritten public offering, as well as its June 2016 
underwritten public offering of convertible senior notes due in 2021. The Company’s ability to continue to meet its 
obligations and to achieve its business objectives for the foreseeable future is dependent upon, amongst other things, 
generating sufficient revenues and its ability to continue to control expenses, if necessary, to meet its obligations as 
they become due. Failure to increase sales of its products, manage discretionary expenditures or raise additional 
financing, if required, may adversely impact the Company’s ability to achieve its intended business objectives. 

Public Offerings 

In November 2014, the Company completed its initial public offering (IPO) of shares of its common stock and 

as a result, the following transactions were recorded in the Company’s consolidated financial statements during the 
fourth quarter of 2014: 

 

 

the sale of 8,050,000 shares of common stock, including 1,050,000 from the exercise by the 
underwriters of their overallotment option, at an offering price of $18.00 per share, for net proceeds of 
$131.6 million, after deducting the underwriters’ discounts, commissions and offering costs paid by us; 
and 

immediately prior to the completion of the IPO, all the outstanding shares of the Company’s redeemable 
convertible preferred stock and convertible preferred stock were converted into 15,208,048 shares of 
common stock. 

In June 2015, the Company completed an underwritten public offering of its common stock, which included 

shares of its common stock held by certain of its stockholders, and issued 2,470,587 shares of common stock, 
including 705,882 shares issued pursuant to the exercise in full by the underwriters of their option to purchase 
additional shares.  The Company received cash proceeds of approximately $118.4 million, net of underwriting 
discounts and commissions and offering costs paid by the Company. 

In June 2016, the Company issued $150.0 million aggregate principal amount of 1.75% convertible senior 

notes due 2021 in a registered underwritten public offering and an additional $22.5 million aggregate principal 
amount of such notes pursuant to the exercise in full of the over-allotment options of the underwriters (the 2021 
Notes). The interest rates are fixed at 1.75% per annum and are payable semi-annually in arrears on June 1 and 
December 1 of each year, commencing on December 1, 2016.  The total net proceeds from the debt offering, after 
deducting transaction costs, were approximately $166.2 million. 

2. Summary of Significant Accounting Policies 

Basis of Presentation 

These consolidated financial statements have been prepared in accordance with accounting principles 

generally accepted in the U.S. (U.S. GAAP). The consolidated financial statements include the Company’s accounts 
and those of its four wholly owned subsidiaries. All intercompany accounts and transactions have been eliminated. 

85 

 
Segments 

The chief operating decision maker for the Company is the Chief Executive Officer. The Chief Executive 
Officer reviews financial information presented on a consolidated basis, accompanied only by information about 
revenue by geographic region. The Company has one business activity and there are no segment managers who are 
held accountable for operations, operating results or plans for levels or components below the consolidated unit 
level, other than revenue. Accordingly, the Company has determined that it has a single reportable and operating 
segment structure. The Company and its Chief Executive Officer evaluate performance based primarily on revenue 
in the geographic locations in which the Company operates.  

The Company historically derived most of its revenue from sales to customers in Australia and Europe.  In 
May 2015, the U.S. Food and Drug Administration (FDA) approved the Company’s premarket approval (PMA) 
application to market Senza in the United States and the Company launched sales in the United States in 2015. 
Revenue by geography is based on the billing address of the customer. The following table sets forth revenue by 
geographic area for countries with revenue accounting for 10% of more of the total revenue during the periods 
presented: 

Years Ended December 31, 
2015 

2016 

2014 

United States 
Australia 
United Kingdom 
Germany 

* 

Represents less than 10% 

76% 
*    
*    
*    

35 %    
20 %    
12 %    
13 %    

— %
35 %
18 %
17 %

Long-lived assets and operating income outside the U.S. are not material; therefore disclosures have been 

limited to revenue. 

Foreign Currency Translation 

The Company’s consolidated financial statements are prepared in U.S. dollars (USD). Its foreign subsidiaries 

use their local currency as their functional currency and maintain their records in the local currency. Accordingly, 
the assets and liabilities of these subsidiaries are translated into USD using the current exchange rates in effect at the 
balance sheet date and equity accounts are translated into USD using historical rates. Revenues and expenses are 
translated using the monthly average exchange rates during the period when the transaction occurs. The resulting 
foreign currency translation adjustments from this process are recorded in accumulated other comprehensive income 
(loss) in the consolidated balance sheets. Unrealized foreign exchange gains and losses from the remeasurement of 
assets and liabilities denominated in currencies other than the functional currency of the reporting entity are 
recorded in other income (expense), net. The Company recorded net unrealized foreign currency transaction losses 
of $1.6 million during the year ended December 31, 2016, gains of $0.6 million during the year ended December 31, 
2015 and losses of $1.1 million during the year ended December 31, 2014. Additionally, realized gains and losses 
resulting from transactions denominated in currencies other than the local currency are recorded in other income 
(expense), net. The Company recorded realized foreign currency transaction gains of $0.7 million during the year 
ended December 31, 2016, and losses of $2.2 million and $0.6 million during the years ended December 31, 2015 
and 2014, respectively. 

As the Company’s international operations grow, the effect of fluctuations in currency rates will become 

greater, and the Company will continue to reassess its approach to managing this risk. In addition, currency 
fluctuations or a weakening U.S. dollar can increase the costs of the Company’s international expansion. To date, 
the Company has not entered into any foreign currency hedging contracts. Based on its current international 
structure, the Company does not plan on engaging in hedging activities in the near future. 

86 

 
 
  
 
  
  
 
  
 
  
  
  
 
 
 
 
 
Use of Estimates 

The preparation of financial statements in accordance with accounting principles generally accepted in the 

United States of America requires management to make estimates and assumptions that affect the amounts reported 
in the consolidated financial statements and accompanying notes. Significant accounting estimates and management 
judgments reflected in the consolidated financial statements include items such as allowances for doubtful accounts; 
warranty obligations; stock-based compensation; depreciation and amortization lives; inventory valuation; valuation 
of investments and deferred tax assets, including valuation allowances. Estimates are based on historical experience, 
where applicable, and other assumptions believed to be reasonable by the management. Actual results may differ 
from those estimates under different assumptions or conditions. 

Concentration of Credit Risk and Other Risks and Uncertainties 

Financial instruments that potentially subject the Company to a concentration of credit risk consist of cash, 
cash equivalents and investments. The majority of the Company’s cash is held by one financial institution in the 
United States in excess of federally insured limits. The Company maintained investments in money market funds 
that were not federally insured during the years ended December 31, 2016 and 2015, and held cash in foreign banks 
of approximately $3.3 million and $5.2 million at December 31, 2016 and 2015, respectively, that was not federally 
insured. The Company has not experienced any losses on its deposits of cash and cash equivalents. 

Through December 31, 2014, all of the Company’s revenue had been derived from sales of its products in 

international markets, principally Australia and Europe.  In May 2015, the Company launched sales in the United 
States upon receiving FDA approval to market and sell its products in the United States. In the international markets 
in which the Company participates, the Company uses both a direct sales force and distributors to sell its products, 
while in the United States the Company utilizes a direct sales force. The Company performs ongoing credit 
evaluations of its direct customers and distributors, does not require collateral, and maintains allowances for 
potential credit losses on customer accounts when deemed necessary. 

There were no customers that accounted for 10% or more of the Company’s revenue for each of the years 

ended December 31, 2016, 2015 and 2014.  There were no customers that accounted for 10% or more of the 
Company’s accounts receivable balance as of December 31, 2016 and 2015. 

The Company is subject to risks common to medical device companies including, but not limited to, new 
technological innovations, dependence on key personnel, protection of proprietary technology, compliance with 
government regulations, product liability, uncertainty of market acceptance of products, and the need to obtain 
additional financing. The Company is dependent on third party manufacturers and suppliers, in some cases sole- or 
single-source suppliers. 

There can be no assurance that the Company’s products or services will continue to be accepted in the 
marketplace, nor can there be any assurance that any future products or services can be developed or manufactured 
at an acceptable cost and with appropriate performance characteristics, or that such products or services will be 
successfully marketed, if at all. 

The Company expects to incur substantial operating losses in the near term and may need to obtain additional 

financing. There can be no assurance that such financing will be available or will be at terms acceptable by the 
Company. 

Fair Value of Financial Instruments 

Carrying amounts of certain of the Company’s financial instruments, including cash equivalents, short term 

investments, accounts receivable, accounts payable and accrued liabilities approximate fair value due to their 
relatively short maturities. 

87 

 
Cash and Cash Equivalents 

The Company considers all highly liquid investments purchased with an original maturity of three months or 

less at the date of purchase to be cash equivalents. Cash and cash equivalents include money market funds in the 
amount of $35.5 million and $36.6 million as of December 31, 2016 and 2015, respectively. At December 31, 2016 
and 2015, the Company’s cash equivalents were held in institutions in the United State and include commercial 
paper deposits in a money market fund which were unrestricted as to withdrawal or use. 

Restricted Cash 

Restricted cash as of December 31, 2016 and 2015 includes a letter of credit of $0.6 million representing 
collateral for the Company’s Redwood City, CA building lease pursuant to an agreement dated March 5, 2015.  
Restricted cash additionally includes certificates of deposit of $0.2 million as of December 31, 2016 and $0.3 
million as of December 31, 2015, collateralizing payment of charges related to the Company’s credit cards. 

Investment Securities 

The Company classifies its investment securities as available-for-sale. The Company classifies these 
investment securities as short-term or long-term based on the nature of the investment, its maturity date and its 
availability for use in current operations. Those investments with original maturities greater than three months at the 
date of purchase and remaining maturities of less than 12 months are considered short-term investments. Those 
investments with remaining maturities greater than 12 months are also classified as short-term investments as 
management considers them to be available for current operations if needed. The Company’s investment securities 
are recorded at fair value based on the fair value hierarchy.  Money market funds and treasury bonds are classified 
within Level 1 of the fair value hierarchy and the commercial paper and corporate notes are classified within Level 2 
of the fair value hierarchy. Unrealized gains and losses, deemed temporary in nature, are reported as a separate 
component of accumulated other comprehensive income (loss). 

A decline in the fair value of any security below cost that is deemed other than temporary results in a charge to 

earnings and the corresponding establishment of a new cost basis for the security. Premiums (discounts) are 
amortized (accreted) over the life of the related security as an adjustment to yield using the straight-line interest 
method. Dividend and interest income are recognized when earned. Realized gains and losses are included in 
earnings and are derived using the specific identification method for determining the cost of securities sold. 

Inventories 

Inventories are stated at the lower of cost to purchase or manufacture the inventory or the market value of such 
inventory. Cost is determined using the standard cost method which approximates the first-in, first-out basis. Market 
value is determined as the lower of replacement cost or net realizable value. The Company regularly reviews 
inventory quantities in consideration of actual loss experiences, projected future demand, and remaining shelf life to 
record a provision for excess and obsolete inventory when appropriate. 

The Company’s policy is to write down inventory that has become obsolete, inventory that has a cost basis in 
excess of its expected lower of cost or market value, and inventory in excess of expected requirements. The estimate 
of excess quantities is subjective and primarily dependent on the Company’s estimates of future demand for a 
particular product. If the estimate of future demand is inaccurate based on actual sales, the Company may increase 
the write down for excess inventory for that component and record a charge to inventory impairment in the 
accompanying consolidated statements of operations and comprehensive loss. The Company periodically evaluates 
the carrying value of inventory on hand for potential excess amount over demand using the same lower of cost or 
market approach as that has been used to value the inventory. The Company also periodically evaluates inventory 
quantities in consideration of actual loss experience. As a result of these evaluations, for the years ended 
December 31, 2016, 2015 and 2014, the Company recognized total write downs of $4.1 million, $2.8 million and 
$0.8 million for its inventories. The Company’s estimation of the future demand for a particular component of the 
Company’s products may vary and may result in changes in estimates in any particular period. 

88 

 
Shipping and Handling Costs 

Shipping and handling costs are expensed as incurred and are included in cost of revenue. 

Revenue Recognition 

The Company recognizes revenue when all of the following criteria are met: 

 

 

 

 

persuasive evidence of an arrangement exists; 

the sales price is fixed or determinable; 

collection of the relevant receivable is reasonably assured at the time of sale; and 

delivery has occurred or services have been rendered. 

For a majority of sales, where the Company’s sales representative delivers its product at the point of 
implantation at hospitals or medical facilities, the Company recognizes revenue upon completion of the procedure 
and authorization, which represents satisfaction of the required revenue recognition criteria. For the remaining sales, 
which are sent from the Company’s distribution centers directly to hospitals and medical facilities, as well as 
distributor sales where product is ordered in advance of an implantation procedure and a valid purchase order has 
been received, the Company recognizes revenue at the time of shipment of the product, which represents the point in 
time when the customer has taken ownership and assumed the risk of loss and the required revenue recognition 
criteria are satisfied. The Company’s customers are obligated to pay within specified terms regardless of when or if 
they ever sell or use the products. The Company does not offer rights of return or price protection and it has no post-
delivery obligations. The Company periodically provides incentive offers to customers.  Product revenue is recorded 
net of such incentive offers. 

Allowance for Doubtful Accounts 

The Company makes estimates of the collectability of accounts receivable. In doing so, the Company analyzes 

historical bad debt trends, customer credit worthiness, current economic trends and changes in customer payment 
patterns when evaluating the adequacy of the allowance for doubtful accounts. 

Warranty Obligations 

The Company has a limited one- to five-year warranty to most customers and warrants that its products will 

operate substantially in conformity with product specifications. The Company records an estimate for the provision 
for warranty claims in cost of revenue when the related revenues are recognized.  This estimate is based on historical 
and anticipated rates of warranty claims, the cost per claim and the number of units sold.  The Company regularly 
assesses the adequacy of its recorded warranty obligations and adjusts the amounts as necessary. 

Property and Equipment 

Property and equipment are stated at cost less accumulated depreciation and amortization. Depreciation of 
property and equipment, other than leasehold improvements, is computed using the straight-line method over the 
assets’ estimated useful lives of three to five years. Leasehold improvements are amortized on a straight-line basis 
over the shorter of the estimated useful life of the asset or the life of the lease. Upon retirement or sale, the cost and 
related accumulated depreciation are removed from the consolidated balance sheet and the resulting gain or loss is 
reflected in operations. Maintenance and repairs are charged to operations as incurred. 

Impairment of Long-Lived Assets 

The Company reviews long-lived assets for impairment whenever events or changes in circumstances indicate 

that the carrying amount of an asset or asset group might not be recoverable. When such an event occurs, 
management determines whether there has been impairment by comparing the anticipated undiscounted future net 
cash flows to the related asset group’s carrying value. If an asset is considered impaired, the asset is written down to 
fair value, which is determined based either on discounted cash flows or appraised value, depending on the nature of 

89 

 
the asset. There were no impairment charges, or changes in estimated useful lives, recorded through December 31, 
2016. 

Income Taxes 

The Company records income taxes using the asset and liability method, which requires the recognition of 
deferred tax assets and liabilities for the expected future tax consequences of events that have been recognized in the 
Company’s consolidated financial statements or income tax returns. In estimating future tax consequences, expected 
future events other than enactments or changes in the tax law or rates are considered. Valuation allowances are 
provided when necessary to reduce deferred tax assets to the amount expected to be realized. 

The Company operates in various tax jurisdictions and is subject to audit by various tax authorities. To date, 
taxes paid have been predominantly due to income taxes in foreign jurisdictions in which we conduct business. The 
Company provides for tax contingencies whenever it is deemed probable that a tax asset has been impaired or a tax 
liability has been incurred for events such as tax claims or changes in tax laws. Tax contingencies are based upon 
their technical merits, relative tax law, and the specific facts and circumstances as of each reporting period. Changes 
in facts and circumstances could result in material changes to the amounts recorded for such tax contingencies. 

The Company records uncertain tax positions on the basis of a two-step process whereby (1) a determination 
is made as to whether it is more likely than not that the tax positions will be sustained based on the technical merits 
of the position and (2) for those tax positions that meet the more-likely-than-not recognition threshold the Company 
recognizes the largest amount of tax benefit that is greater than 50% likely to be realized upon ultimate settlement 
with the related tax authority. The Company’s policy is to recognize interest and penalties related to income taxes as 
a component of income tax expense. No interest or penalties related to income taxes have been recognized in the 
statements of operations and comprehensive loss in 2016 and 2015. 

Other Comprehensive Income (Loss) 

Other comprehensive income (loss) represents all changes in stockholders’ equity except those resulting from 
distributions to stockholders. The Company’s unrealized gains on short-term available-for-sale investment securities 
and foreign currency translation adjustments represent the components of other comprehensive income (loss) that 
are excluded from the reported net loss and are presented in the consolidated statements of operations and 
comprehensive loss. 

Research and Development 

Research and development expenses, including new product development, regulatory compliance, and clinical 
research, are charged to operations as incurred in the consolidated statements of operations and comprehensive loss. 
Such costs include personnel-related costs, including stock-based compensation, supplies, services, depreciation, 
allocated facilities and information services, clinical trial and related clinical manufacturing expenses, fees paid to 
investigative sites, and other indirect costs. 

Stock-Based Compensation 

The Company accounts for stock-based compensation arrangements with employees in accordance with 

Accounting Standards Codification (ASC) 718, Compensation—Stock Compensation. ASC 718 requires the 
recognition of compensation expense, using a fair value-based method, for costs related to all share-based payments 
including stock options. 

The Company’s determination of the fair value of stock options on the date of grant utilizes the Black-Scholes 

option-pricing model, and is impacted by its common stock price as well as changes in assumptions regarding a 
number of highly complex and subjective variables. These variables include, but are not limited to, the expected 
term that options will remain outstanding, the expected common stock price volatility over the term of the option 
awards, risk-free interest rates and expected dividends. 

90 

 
The fair value of stock options is recognized over the period during which an optionee is required to provide 
services in exchange for the option award, known as the requisite service period (usually the vesting period), on a 
straight-line basis, with the exception of performance based stock options whose fair value is recorded as expenses 
when performance metrics are achieved. Stock-based compensation expense recognized at fair value includes the 
impact of estimated forfeitures. The Company estimates future forfeitures at the date of grant and revises the 
estimates, if necessary, in subsequent periods if actual forfeitures differ from those estimates. 

The Company accounts for restricted stock units at their fair value, based on the closing market price of the 
Company’s common stock on the grant date. The fair value is amortized on a straight-line basis over the requisite 
service period of the awards, with the exception of performance based awards whose fair value is recorded as 
expenses when performance metrics are achieved. 

The Company estimates the fair value of the rights to purchase shares by employees under the Employee 
Stock Purchase Plan using the Black-Scholes option pricing formula. The Employee Stock Purchase Plan provides 
for consecutive six-month offering periods and the Company uses its own historical volatility data in the valuation. 

Equity instruments issued to non-employees are recorded at their fair value on the measurement date and are 

subject to periodic adjustments as the underlying equity instruments vest. The fair value of options granted to 
consultants is expensed when vested. The non-employee stock-based compensation expense was not material for all 
periods presented. 

Estimating the fair value of equity-settled awards as of the grant date using valuation models, such as the 
Black-Scholes option pricing model, is affected by assumptions regarding a number of complex variables. Changes 
in the assumptions can materially affect the fair value and ultimately how much stock-based compensation expense 
is recognized. These inputs are subjective and generally require significant analysis and judgment to develop. For all 
stock options granted to date, we included the volatility data based on a study of publicly traded industry peer 
companies. For purposes of identifying these peer companies, we considered the industry, stage of development, 
size and financial leverage of potential comparable companies. The risk-free interest rate is based on the yield 
available on U.S. Treasury zero-coupon issues similar in duration to the expected term of the equity-settled award. 

The Company accounts for stock-based compensation for the restricted stock units at their fair value, based on 

the closing market price of the Company’s common stock on the grant date.  These costs are recognized on a 
straight-line basis over the requisite service period, which is generally the vesting term of four years. 

The Company recognizes a benefit from stock-based compensation as additional paid-in capital if an 

incremental tax benefit is realized by following the with-and-without approach. 

Net Loss per Share of Common Stock 

Basic net loss per common share is calculated by dividing the net loss attributable to common stockholders by 
the weighted-average number of common shares outstanding during the period, without consideration for potentially 
dilutive securities. Diluted net loss per share is computed by dividing the net loss attributable to common 
stockholders by the weighted-average number of common shares and potentially dilutive securities outstanding for 
the period. For purposes of the diluted net loss per share calculation, restricted stock units and common stock 
options are considered to be potentially dilutive securities. Because the Company has reported a net loss in all 
periods presented, diluted net loss per common share is the same as basic net loss per common share for those 
periods. 

Recent Accounting Pronouncements 

In July 2015, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) 

No. 2015-11, Inventory (Topic 330): Simplifying the Measurement of Inventory, which permits companies to 
measure inventory at the lower of cost and realizable value. ASU 2015-11 applies to all business entities and is 
effective for public business entities for annual periods, and interim periods within those annual periods, beginning 
after December 15, 2016. Early adoption is permitted. Although the Company is currently evaluating the impact of 

91 

 
this guidance, it does not believe that the guidance will have a material impact on its consolidated financial 
statements. 

In May 2014, the FASB issued ASU No. 2014-09, Revenue from Contracts with Customers (Topic 606), 

which supersedes the revenue recognition requirements in ASC 605, Revenue Recognition. This ASU is based on 
the principle that revenue is recognized to depict the transfer of goods or services to customers in an amount that 
reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. The 
ASU also requires additional disclosure about the nature, amount, timing and uncertainty of revenue and cash flows 
arising from customer contracts, including significant judgments and changes in judgments and assets recognized 
from costs incurred to obtain or fulfill a contract.  In August 2015, FASB issued ASU No. 2015-14, Revenue from 
Contracts with Customers (Topic 606): Deferral of the Effective Date, which effectively delayed the adoption date 
by one year, to an effective date for public entities for annual and interim periods beginning after December 15, 
2017. In April 2016, FASB issued ASU No. 2016-10, Revenue from Contracts with Customers (Topic 606): 
Identifying Performance Obligations and Licensing, which clarifies the aspects of Topic 606 that relates to 
identifying performance obligations and licensing implementation guidance.  In May 2016, the FASB issued ASU 
No. 2016-12, Revenue from Contracts with Customers (Topic 606): Narrow-Scope Improvements and Practical 
Expedients, related to disclosures of remaining performance obligations, as well as other amendments to guidance 
on collectability, non-cash consideration and the presentation of sales and other similar taxes collected from 
customers. In December 2016, the FASB issued ASU 2016-20, Technical Corrections and Improvements to Topic 
606, Revenue from Contracts and Customers, related to further clarifications issued in ASU 2014-09.  The effective 
dates of ASU 2016-10, ASU 2016-12 and ASU 2016-20 are the same as that of ASU 2014-09.  The guidance is 
required to be applied retrospectively to each prior reporting period presented, or retrospectively with the cumulative 
effect of initially applying it recognized at the date of initial application.  The Company is currently evaluating the 
full impact of this guidance on its consolidated financial statements, including the selection of a transition method. 

In January 2016, the FASB issued ASU 2016-01, Recognition and Measurement of Financial Assets and 

Financial Liabilities, which addresses certain aspects of recognition, measurement, presentation and disclosure of 
financial instruments. ASU 2016-01 is effective for annual periods, and interim periods within those annual periods, 
beginning after December 15, 2017. The Company has not determined the potential effects of this ASU on its 
consolidated financial statements. 

In February 2016, the FASB issued ASU No. 2016-02, Leases (Topic 842). This update requires an entity to 
recognize assets and liabilities for leases with lease terms of more than 12 months on the balance sheet. ASU 2016-
02 is effective for public entities for fiscal years beginning after December 15, 2018.  Although the Company is 
currently evaluating the impact of this guidance on its consolidated financial statements and related disclosures, the 
Company expects that most of its operating lease commitments will be subject to the new standard and recognized 
as operating lease liabilities and right-of-use assets upon adoption. 

In March 2016, the FASB issued ASU No. 2016-09, Compensation-Stock Compensation (Topic 718): 
Improvements to Employee Share-Based Payment Accounting. This update simplifies the accounting for employee 
share-based payment transactions, including the accounting for income taxes, forfeitures and statutory tax 
withholding requirements, as well as classification in the statement of cash flows. ASU 2016-09 is effective for 
public entities for annual periods beginning after December 15, 2016.  Although the Company is currently 
evaluating the full impact of this guidance, the Company does not expect the adoption of this guidance to have a 
material impact on its consolidated financial statements. 

In June 2016, the FASB issued ASU No. 2016-13, Financial Instruments – Credit Losses (Topic 326): 
Measurement of Credit Losses on Financial Instruments.  This update changes the accounting for recognizing 
impairments of financial assets, such that credit losses for certain types of financial instruments will be estimated 
based on expected losses. The update also modifies the impairment models for available-for-sale debt securities and 
for purchased financial assets with credit deterioration since their origination. ASU 2016-13 is effective for public 
entities for annual periods beginning after December 15, 2019. Early adoption is permitted after December 15, 2018.  
The Company has not determined the potential effects of this ASU on its consolidated financial statements. 

In August, 2016, the FASB issued ASU No. 2016-15, Classification of Certain Cash Receipts and Cash 

Payments (a consensus of the Emerging Issues Task Force). The update clarifies the classification of certain cash 

92 

 
receipts and cash payments in the statement of cash flows, including debt prepayment or extinguishment costs, 
settlement of contingent consideration arising from a business combination, insurance settlement proceeds and 
distributions from certain equity method investees. ASU 2016-15 is effective for fiscal years, and interim periods 
within those fiscal years, beginning after December 15, 2017. Early adoption is permitted. The Company has not 
determined the potential effects of the guidance on its consolidated financial statements. 

In October 2016, the FASB issued ASU No. 2016-16, Income Taxes (Topic 740): Intra-Entity Transfers of 

Assets Other than Inventory. This update is intended to reduce the complexity and diversity in practice related to the 
tax consequences of certain types of intra-entity asset transfers.  Under this ASU, a selling entity is required to 
recognize a current tax expense or benefit upon the transfer of the asset. Similarly, the purchasing entity is required 
to recognize a deferred tax asset or liability, as well as the related deferred tax benefit or expense, upon receipt of the 
asset. This ASU does not apply to intra-entity transfers of inventory, where the income tax consequences from the 
sale of inventory from one member of a consolidated entity to another will continue to be deferred until the 
inventory is sold to a third party. ASU 2016-16 is effective for public entities for annual periods beginning after 
December 15, 2017, and interim periods within those annual periods.  Early adoption is permitted.  The Company 
has not determined the potential effects of the guidance on its consolidated financial statements. 

In November 2016, the FASB issued ASU No. 2016-18, Statement of Cash Flows (Topic 230): Restricted 

Cash, a consensus of the FASB Emerging Issues Task Force. The update requires that the statement of cash flows 
explain the change during the period in the total of cash, cash equivalents, and amounts generally described as 
restricted cash or restricted cash equivalents. ASU 2016-18 is effective for public entities for annual periods 
beginning after December 15, 2017, and interim periods within those annual periods. The Company has not 
determined the potential effects of the guidance on its consolidated financial statements. 

3. Fair Value Measurements 

Fair value is defined as the exchange price that would be received for an asset or an exit price paid to transfer 

a liability in the principal or most advantageous market for the asset or liability in an orderly transaction between 
market participants on the measurement date. Valuation techniques used to measure fair value must maximize the 
use of observable inputs and minimize the use of unobservable inputs. 

The fair value hierarchy defines a three-level valuation hierarchy for disclosure of fair value measurements as 

follows: 

 

 

 

Level 1 — Observable inputs, such as quoted prices in active markets for identical assets or liabilities. 

Level 2 — Observable inputs other than Level 1 prices, such as quoted prices for similar assets or 
liabilities, quoted prices in markets that are not active, or other inputs that are observable or can be 
corroborated by observable market data for substantially the full term of the assets or liabilities. 

Level 3 — Unobservable inputs that are supported by little or no market activity and that are significant 
to the fair value of the assets or liabilities. 

93 

 
Cash Equivalents and Short Term Investments 

The Company’s cash equivalents are comprised of investments in money market funds that are classified as 

Level 1 of the fair value hierarchy. To value its money market funds, the Company values the funds at $1 stable net 
asset value, which is the quoted price in active markets for identical assets that the Company has the ability to 
access. The Company’s short-term investments are comprised of commercial paper, corporate notes and U.S. 
government agency obligations. All short-term investments have been classified within Level 1 or Level 2 of the fair 
value hierarchy because of the sufficient observable inputs for revaluation. The Company’s Level 2 investments are 
valued using third-party pricing sources. The pricing services utilize industry standard valuation models, including 
both income and market-based approaches, for which all significant inputs are observable, either directly or 
indirectly, to estimate fair value. These inputs include reported trades of any broker/dealer quotes on the same or 
similar investments, issuer credit spreads, benchmark investments, prepayment/default projections based on 
historical data and other observable inputs. The following table sets forth the Company’s financial instruments that 
were measured at fair value on a recurring basis, by level, within the fair value hierarchy (in thousands): 

Balance as of December 31, 2016 
Assets: 
Money market funds (i) 
Commercial paper (iii) 
Corporate notes (iii) 
Total assets 

Balance as of December 31, 2015 
Assets: 
Money market funds (i) 
Commercial paper (ii) 
Treasury bonds (iii) 
Total assets 

  Level 1 

    Level 2 

    Level 3 

Total 

  $

  $

35,510    $

—    $
—      160,582     
74,369     
—     
35,510    $ 234,951    $

—     $  35,510 
—        160,582 
—       
74,369 
—     $  270,461  

  Level 1 

    Level 2 

    Level 3 

Total 

  $

  $

36,559    $

—    $
—      129,206     
—     
10,617     
47,176    $ 129,206    $

—     $  36,559 
—        129,206 
10,617 
—       
—     $  176,382  

(i) 

Included in cash and cash equivalents on the consolidated balance sheets. 

(ii) 

Included in either cash and cash equivalents or short-term investments on the consolidated balance sheets. 

(iii) 

Included in short-term investments on the consolidated balance sheets. 

Convertible Senior Notes 

As of December 31, 2016, the fair value of the 1.75% convertible senior notes due 2021 was $183.8 million.  

The fair value was determined on the basis of market prices observable for similar instruments and is considered 
Level 2 in the fair value hierarchy. 

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4. Balance Sheet Components 

Investments 

The fair value of the Company’s cash equivalents and short-term investments approximates their respective 
carrying amounts due to their short-term maturity. The following is a summary of the gross unrealized gains and 
unrealized losses on the Company’s investment securities (in thousands): 

Investment Securities 
Commercial paper 
Corporate notes 

Total securities 

Investment Securities 

Commercial paper (i) 
Treasury bonds 

Total securities 

December 31, 2016 
Gross 
Unrealized 
Holding 
Losses 

Gross 
Unrealized
Holding 
Gains

Amortized
Cost

Aggregate 
Fair Value  

  $ 160,729    $
74,430     
  $ 235,159    $

6    $
3     
9    $

(153 )   $  160,582 
74,369 
(64 )     
(217 )   $  234,951  

December 31, 2015 
Gross 
Unrealized 
Holding 
Losses 

Gross 
Unrealized
Holding 
Gains

Amortized
Cost

Aggregate 
Fair Value  

  $ 129,075    $
10,616     
  $ 139,691    $

131    $
1     
132    $

—     $  129,206 
—       
10,617 
—     $  139,823  

(i) 

Includes $33.2 million of commercial paper that is classified as cash and cash equivalents on the consolidated 
balance sheet. 

Realized gains or losses from the sale of investments and other-than-temporary impairments, if any, on 
available-for-sale securities are reported in other income (expense), net as incurred. The cost of securities sold was 
determined based on the specific identification method. The Company has not recorded any realized gains, realized 
losses or impairment on its investments during the periods presented. 

The amortized costs and estimated fair values of the Company’s available-for-sale securities by contractual 

maturities as of December 31, 2016 were as follows (in thousands): 

Amounts maturing within one year 
Amounts after one year through five years 

Total investment securities 

Inventories, Net (in thousands) 

Raw materials 
Finished goods 

Total inventories 

Amortized 
Cost 

    Fair Value    

  $ 233,163   $ 232,955   
1,996   
  $ 235,159   $ 234,951   

1,996    

December 31, 

2016 
44,862   $
40,359    
85,221   $

2015 
37,096   
25,334   
62,430   

  $

  $

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Property and Equipment, Net (in thousands) 

Laboratory equipment 
Computer equipment and software 
Furniture and fixtures 
Leasehold improvements 
Construction in process 

Total 

Less: Accumulated depreciation and amortization 

Property and equipment, net 

December 31, 

2016 

2015 

  $

  $

1,567    $
2,388     
2,051     
1,214     
2,274     
9,494     
(2,362)   
7,132    $

921   
1,836   
1,752   
1,188   
799   
6,496   
(702 ) 
5,794   

Depreciation and amortization expense for the years ended December 31, 2016, 2015 and 2014 was $1.7 

million, $0.6 million and $96,000, respectively. 

Accrued Liabilities (in thousands) 

Accrued payroll and related expenses 
Accrued professional fees 
Accrued taxes 
Accrued clinical and research expenses 
Accrued interest 
Accrued warranty 
Accrued other 

Total accrued liabilities 

December 31, 

2016 
17,732   $
1,067    
2,110    
1,545    
243    
645    
2,686    
26,028   $

2015 

9,857   
583   
2,044   
405   
—   
394   
1,098   
14,381   

  $

  $

5. Commitments and Contingencies 

Operating Leases 

In March 2015, the Company entered into a lease agreement for approximately 50,000 square feet of office 

space located in Redwood City, California for a period beginning in June 2015 through May 2022 with initial annual 
payments of approximately $2.0 million, increasing to $2.4 million annually during the final year of the lease term. 
In December 2016, the Company entered into an amendment for an additional approximately 50,000 square feet of 
office space adjacent to the premises under the original lease (the Expansion Premises), with initial annual payments 
of $1.2 million, increasing to $2.9 million in the final year of the amended lease term.  The lease for the Expansion 
Premises commences on the earlier of (i) the date the Company commences business operations in the Expansion 
Premises, or (ii) the date upon which the Landlord substantially completes certain improvements to, and permitting 
for, the Expansion Premises (the Commencement Date). The amendment also extends the lease term for the original 
premises to terminate on the same date as the amended lease.  Under the amendment, if the Company is unable to 
move into the Expansion Premises before the Scheduled Delivery Date, as defined in the amendment, the Company 
may terminate the lease for the Expansion Premises. 

The Company entered into a non-cancellable operating lease effective May 1, 2010 for facilities in Menlo 
Park, CA as amended in 2012 to extend the period of the lease until May 31, 2015. In March 2015, the Company 
extended the lease through September 30, 2015, at which time the lease terminated. In August 2014, the Company 
entered into a new facility lease for warehouse space beginning on August 21, 2014 through May 31, 2015, under 
which it is obligated to pay approximately $100,000 in lease payments over the term of the lease. In March 2015, the 
Company extended the warehouse lease through February 2017 under which it is obligated to pay approximately 
$0.3 million in lease payments over the remaining term of the lease. 

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Rent expense for the years ended December 31, 2016, 2015 and 2014 was $2.4 million, $1.9 million and $0.7 

million, respectively. 

Excluding the terms under the amendment for the Expansion Premises, which is subject to certain cancellation 

clauses, future minimum lease payments under operating leases as of December 31, 2016 are as follows (in 
thousands): 

Year ending December 31, 
2017 
2018 
2019 
2020 
2021 
Thereafter 
Total 

   Operating Lease  

   $

   $

2,167  
2,185  
2,250  
2,318  
2,387  
1,211  
12,518   

Warranty Obligations 

The Company warrants that its products will operate substantially in conformity with product specifications 

and has a limited one- to five-year warranty to most customers.  The Company established a warranty liability in 
June 2015.  Prior to that time, replacements made under warranty were minimal and were recorded at the time that 
the claims were incurred.  Activities related to warranty obligations were as follows (in thousands): 

Beginning Balance 
Provision for warranty 
Utilization 
Ending Balance 

December 31, 

2016 

2015 

  $

  $

394    $
902     
(651)   
645    $

—   
451   
(57 ) 
394   

Supply Agreements 

The Company has entered into supply agreements with certain of the Company’s suppliers that required 
certain minimum annual purchase agreements.  As of December 31, 2016, the Company had minimum annual 
purchase commitments $25.0 million due in 2017 and $5.5 million due in each of 2018, 2019, 2020 and 2021. 

License Agreement 

In March 2006, the Company entered into an amended and restated license agreement with the Mayo 

Foundation for Medical Education and Research (Mayo) and Venturi Group LLC (VGL), which provides the 
Company access to the certain know how and licensed patents owned by Mayo and VGL for treatment of central, 
autonomic and peripheral nervous system disorders, including pain, using devices to modulate nerve signaling. The 
licenses granted are exclusive and the Company has the right to sub-license. The agreement will terminate upon the 
last to expire patent application, unless terminated earlier. The agreement can be terminated any time after three 
years from March 2006 by Mayo or VGL. 

Per terms of the license, the Company is required to pay royalties based on the greater of earned royalty or 
minimum royalty. The earned royalty will be based on a percentage of net sales of licensed products either by the 
Company or the sub-licensee. The minimum royalty payment will be based on royalty periods as defined in the 
agreement. 

In March 2011, the Company entered into a Phase II License Agreement with Mayo which provides the 
Company access to the certain know how and licensed patents owned by Mayo. The licenses granted are exclusive 

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and the Company has the right to sub-license. The agreement will terminate upon the last to expire patent 
application, unless terminated earlier. 

Per terms of the license, the Company is required to: 

 

 

Pay a retainer fee of $40,000 per annum starting March 2011 and ending February 2013; 

Pay royalties based on the greater of earned royalty or minimum royalty. The earned royalty will be 
based on a percentage of net sales of licensed products either by the Company or the sub-licensee. The 
minimum annual royalty payment is $200,000. 

Royalties paid during the years ended December 31, 2016, 2015 and 2014 were $1.9 million, $0.6 million and 

$0.3 million, respectively. 

In November 2014, the Company issued Mayo 20,833 shares of common stock owed in connection with the 
IPO pursuant to the terms of the license, and recorded noncash research and development expense of $0.5 million 
for the fair value of the shares on the date of issuance. 

Contingencies 

From time to time, the Company may have certain contingent liabilities that arise in the ordinary course of 
business activities. The Company accrues a liability for such matters when it is probable that future expenditures 
will be made and such expenditures can be reasonably estimated. There have been no contingent liabilities requiring 
accrual at December 31, 2016 and 2015. 

Indemnification 

The Company enters into standard indemnification arrangements in the ordinary course of business. Pursuant 

to these arrangements, the Company indemnifies, holds harmless, and agrees to reimburse the indemnified parties 
for losses suffered or incurred by the indemnified party, in connection with any trade secret, copyright, patent or 
other intellectual property infringement claim by any third-party with respect to the Company’s technology. The 
term of these indemnification agreements is generally perpetual. The maximum potential amount of future payments 
the Company could be required to make under these agreements is not determinable because it involves claims that 
may be made against the Company in the future, but have not yet been made. 

The Company has entered into indemnification agreements with its directors and officers that may require the 
Company to indemnify its directors and officers against liabilities that may arise by reason of their status or service 
as directors or officers, other than liabilities arising from willful misconduct of the individual. The maximum 
potential amount of future payments the Company could be required to make under these indemnification 
agreements is unlimited; however, the Company has director and officer insurance coverage that reduces the 
Company’s exposure and enables the Company to recover a portion of any future amounts paid. The Company 
believes the estimated fair value of these indemnification agreements in excess of applicable insurance coverage is 
minimal. 

The Company has not incurred costs to defend lawsuits or settle claims related to these indemnification 

agreements. No liability associated with such indemnifications has been recorded to date. 

Legal Matters 

On November 28, 2016, the Company filed a lawsuit for patent infringement against Boston Scientific 
Corporation and Boston Scientific Neuromodulation Corporation (collectively, Boston Scientific). The lawsuit, filed 
in the United States District Court for the Northern District of California, asserts that Boston Scientific is infringing 
the Company’s patents covering inventions relating to the Senza system and HF10 therapy. The lawsuit seeks 
preliminary and permanent injunctive relief against further infringement as well as damages and attorney’s fees. 

98 

 
On December 9, 2016, Boston Scientific filed a patent infringement lawsuit alleging the Company’s 

manufacture, use and sale of the Senza system infringes certain of Boston Scientific’s patents covering SCS 
technology related to stimulation leads, rechargeable batteries and telemetry. The lawsuit, filed in the United States 
District Court for the District of Delaware, seeks unspecified damages and attorney’s fees, as well as preliminary 
and permanent injunctive relief against further infringement. As of December 31, 2016, the Company did not record 
a liability accrual, as an outcome or potential range of loss cannot be reasonably determined.  

The Company is and may from time to time continue to be involved in various legal proceedings of a 

character normally incident to the ordinary course of its business, including several pending European patent 
oppositions at the European Patent Office (EPO) initiated by the Company’s competitors Medtronic and Boston 
Scientific, which the Company does not deem to be material to its business and consolidated financial statements at 
this stage. 

6. Long-term Debt 

1.75% Convertible Senior Notes and Convertible Note Hedge and Warrant Transactions 

In June 2016, the Company issued $150.0 million aggregate principal amount of 1.75% convertible senior 

notes due 2021 in a registered underwritten public offering and an additional $22.5 million aggregate principal 
amount of such notes pursuant to the exercise in full of the over-allotment options of the underwriters (the 2021 
Notes). The interest rates are fixed at 1.75% per annum and are payable semi-annually in arrears on June 1 and 
December 1 of each year, commencing on December 1, 2016.  The total net proceeds from the debt offering, after 
deducting initial purchase discounts and debt issuance costs, were approximately $166.2 million. 

Each $1,000 principal amount of the 2021 Notes will initially be convertible into 10.3770 shares of the 

Company’s common stock, which is equivalent to an initial conversion price of approximately $96.37 per share, 
subject to adjustment upon the occurrence of specified events. The 2021 Notes will be convertible at the option of 
the holders at any time prior to the close of business on the business day immediately preceding December 1, 2020, 
only under the following circumstances: (1) during any calendar quarter commencing after the calendar quarter 
ending on September 30, 2016 (and only during such calendar quarter), if the last reported sale price of the 
Company’s common stock for at least 20 trading days (whether or not consecutive) during a period of 30 
consecutive trading days ending on the last trading day of the immediately preceding calendar quarter is greater than 
or equal to 130% of the conversion price on each applicable trading day; (2) during the five business day period 
after any ten consecutive trading day period (the measurement period) in which the trading price (as defined in the 
indenture to the 2021 Notes) per $1,000 principal amount of notes for each trading day of the measurement period 
was less than 98% of the product of the last reported sale price of the Company’s common stock and the conversion 
rate on each such trading day; or (3) upon the occurrence of specified corporate events.  On or after December 1, 
2020 until the close of business on the second scheduled trading day immediately preceding the maturity date, 
holders may convert their 2021 Notes at any time, regardless of the foregoing circumstances.  Upon conversion, the 
Company will pay or deliver, as the case may be, cash, shares of the Company’s common stock or a combination of 
cash and shares of the Company’s common stock, at the Company’s election.  If the Company undergoes a 
fundamental change prior to the maturity date, holders of the notes may require the Company to repurchase for cash 
all or any portion of their notes at a repurchase price equal to 100% of the principal amount of the notes to be 
repurchased, plus accrued and unpaid interest to, but excluding, the fundamental change repurchase date. In 
addition, if specific corporate events occur prior to the applicable maturity date, the Company will increase the 
conversion rate for a holder who elects to convert their notes in connection with such a corporate event in certain 
circumstances.  It is the Company’s current intent and policy to settle conversions through combination settlement 
with a specified dollar amount per $1,000 principal amount of notes of $1,000.  During the three months ended 
December 31, 2016, the conditions allowing holders of the 2021 Notes to convert have not been met. The 2021 
Notes are therefore not convertible during the three months ended March 31, 2017 and are classified as long-term 
debt. Should the sale price condition be met in a future quarter, the 2021 Notes will be convertible at the holders’ 
option during the immediately following quarter. As of December 31, 2016, the if-converted value of the 2021 
Notes did not exceed the principal value of those notes. 

In accounting for the issuance of the convertible senior notes, the Company separated the 2021 Notes into 

liability and equity components.  The carrying amount of the liability component was calculated by measuring the 

99 

 
fair value of a similar debt instrument that does not have an associated convertible feature. The carrying amount of 
the equity component representing the conversion option was $32.9 million and was determined by deducting the 
fair value of the liability component from the par value of the 2021 Notes. The equity component is not remeasured 
as long as it continues to meet the conditions for equity classification. The excess of the principal amount of the 
liability component over its carrying amount ("debt discount") is amortized to interest expense over the term of the 
2021 Notes expense at an effective interest rate of 6.29% over the contractual terms of the notes. 

In accounting for the debt issuance costs of $6.2 million related to the 2021 Notes, the Company allocated the 

total amount incurred to the liability and equity components of the 2021 Notes based on their relative values. 
Issuance costs attributable to the liability component were $5.0 million and will be amortized to interest expense 
using the effective interest method over the contractual terms of the 2021 Notes.  Issuance costs attributable to the 
equity component were netted with the equity component in stockholders’ equity. 

The net carrying amount of the liability component of the 2021 Notes was as follows (in thousands): 

Principal 
Unamortized discount 
Unamortized issuance cost 
Net carrying amount 

 $

  December 31,   
2016 
172,500   
(29,783 ) 
(4,577 ) 
138,140   

 $

The net carrying amount of the equity component of the 2021 Notes was as follows (in thousands): 

Debt discount related to value of conversion option 
Debt issuance cost 

Net carrying amount 

December 31,   
2016 

 $

 $

32,945   
(1,179 ) 
31,766   

The following table sets forth the interest expense recognized related to the 2021 Notes (in thousands): 

Year Ended    
December 31, 
2016 

Contractual interest expense 
Amortization of debt discount 
Amortization of debt issuance costs 

  $

Total interest expense related to the 2021 Notes 

  $

1,652  
3,162  
416  
5,230   

In connection with the offering of the 2021 Notes, the Company entered into convertible note hedge 
transactions with certain bank counterparties in which the Company has the option to purchase initially (subject to 
adjustment for certain specified events) a total of approximately 1.8 million shares of the Company’s common stock 
at a price of approximately $96.37 per share. The total cost of the convertible note hedge transactions was $45.1 
million.  In addition, the Company sold warrants to certain bank counterparties whereby the holders of the warrants 
have the option to purchase initially (subject to adjustment for certain specified events) a total of approximately 
1.8 million shares of the Company’s common stock at a price of $127.28 per share. The Company received $33.1 
million in cash proceeds from the sale of these warrants.  Taken together, the purchase of the convertible note 
hedges and the sale of warrants are intended to offset any actual dilution from the conversion of these notes and to 
effectively increase the overall conversion price from $96.37 to $127.28 per share. As these transactions meet 
certain accounting criteria, the convertible note hedges and warrants are recorded in stockholders’ equity and are not 
accounted for as derivatives. The net cost of $12.0 million incurred in connection with the convertible note hedge 
and warrant transactions was recorded as a reduction to additional paid-in capital on the consolidated balance sheet. 

100 

 
 
  
  
 
  
  
  
 
 
  
  
 
  
  
 
 
  
  
 
  
   
   
 
Capital Royalty Term Loan 

On October 24, 2014, the Company entered into a credit facility (the “credit facility”) with Capital Royalty 
Partners and certain of its affiliates (the “lenders”) under which, subject to certain conditions, the Company could 
enter into three term loan agreements totaling $50.0 million with the lenders on or before September 30, 2015. In 
June 2016, the Company paid the outstanding principal and repayment fees totaling $21.0 million to the lenders, and 
the credit facility terminated and is now no longer in effect.  The difference between the total payment to the lenders 
and the net carrying amount of the obligation recorded on the balance sheet was recorded as a loss on 
extinguishment of debt.   

7. Convertible Preferred Stock 

Prior to the initial public offering, the Company had outstanding 15,208,048 shares of convertible preferred 

stock. Each share of preferred stock was convertible to one share of common stock. Upon the closing of the 
Company’s initial public offering on November 11, 2014, all shares of outstanding redeemable convertible preferred 
stock were automatically converted to 15,208,048 shares of the Company’s common stock. 

The Company recorded the Series B and C redeemable convertible preferred stock at fair value on the dates of 

issuance. The Company classified the Series B and C redeemable convertible preferred stock outside of 
stockholders’ deficit because the shares contain liquidation features that are not solely within the Company’s 
control. The Series B and C redeemable convertible preferred shares were originally issued with a contingent 
redemption feature, which allowed the holders to redeem their shares five years following the issuance date of the 
Series B and C redeemable preferred shares. Accordingly, the Company accreted the Series B and C redeemable 
convertible preferred stock for change in redemption value with a charge to accumulated deficit at the end of each 
reporting period. The Company has accreted $0.1 million during the year ended December 31, 2014. 

8. Stock-Based Compensation 

Common stock reserved for future issuance as of December 31, 2016 was as follows: 

Outstanding stock options and restricted stock units 
Reserved for grants of future stock options and 
   restricted stock units 
Reserved for employee stock purchase plan 

Total common stock reserved for future issuance 

  December 31,   
2016 
    3,166,782   

    2,202,239   
621,029   
    5,990,050   

Stock Plans 

The Company’s Board of Directors, or Board, and stockholders previously approved the 2007 Stock Option 

Plan (the “2007 Plan”). In October 2014, the Board adopted the 2014 Equity Incentive Award Plan (the “2014 Plan” 
and, together with the 2007 Plan, the “Stock Plans”).  As of the effective date of the 2014 Plan, the Company 
suspended the 2007 Plan and no additional awards may be granted under the 2007 Plan. Any shares of common 
stock covered by awards granted under the 2007 Plan that terminate after the effective date of the 2014 Plan by 
expiration, forfeiture, cancellation or other means without the issuance of such shares, will be added to the 2014 
Plan reserve. 

Under the 2014 Plan, 1,854,166 shares of common stock were initially reserved for issuance, plus the number 

of shares remaining available for future awards under the 2007 Plan, as of the pricing of the IPO. The number of 
shares initially reserved for issuance under the 2014 Plan is subject to increase by (i) the number of shares 
represented by awards outstanding under the 2007 Plan that are forfeited or lapse unexercised and which following 
the pricing date are not issued under the 2007 Plan, and (ii) an annual increase on January 1 of each year. 

Under the 2014 Plan, the Company may grant awards such as incentive stock options, nonstatutory stock 

options, restricted stock units and stock appreciation rights. Incentive stock options (ISO) may be granted only to 

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Company employees (including directors who are also employees). Nonqualified stock options (NSO) may be 
granted to Company employees, directors and consultants 

Stock Options 

Options under the 2014 Plan may be granted for periods of up to ten years and at prices no less than 100% of 

the estimated fair market value of the shares on the date of grant as determined by the Board, provided, however, 
that the exercise price of an ISO or an NSO granted to a 10% stockholder shall not be less than 110% of the 
estimated fair market value of the shares on the date of grant. Upon the exercise of options, the Company issues new 
common stock from its authorized shares. The vesting provisions of individual options vary but are generally over 
four years, with the exception of performance based stock options. 

Pursuant to the 2014 Plan, the Company granted performance based stock options to the Company’s CEO in 
March 2016. This performance based stock option award is subject to the CEO’s continued service to the Company 
through each applicable vesting date. If a performance metric is not met within the time limits specified in the award 
agreements, the shares subject to vesting under the vesting tranche for that performance metric will be cancelled. 

A summary of shares available for grant under the Stock Plans was as follows: 

Balance at December 31, 2013 
Additional shares reserved 
Options granted 
Options cancelled 
Balance at December 31, 2014 
Additional shares reserved 
Options and restricted stock granted 
Options and restricted stock cancelled 
Balance at December 31, 2015 
Additional shares reserved 
Options and restricted stock granted 
Options and restricted stock cancelled 
Balance at December 31, 2016 

   Shares Available 

for Grant 

581,585 
1,854,166 
(753,102)
12,767 
1,695,416 
994,619 
(975,688)
142,362 
1,856,709 
1,125,742 
(856,043)
75,831 
2,202,239  

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A summary of stock option activity under the Stock Plans was as follows: 

Options Outstanding 
Number of   Weighted Average

Weighted Average     
Remaining 

   Aggregate 

Options 

  Exercise Price  Contractual Term   Intrinsic Value
  (in thousands)
1,655

(in years) 

8.0   $ 

2,731,962  $
Outstanding at December 31, 2013 
753,102  $
Options granted 
(498,565) $
Options exercised 
(12,767) $
Options cancelled 
2,973,732  $
Outstanding at December 31, 2014 
970,238  $
Options granted 
(751,610) $
Options exercised 
(142,072) $
Options cancelled 
3,050,288  $
Outstanding at December 31, 2015 
498,564  $
Options granted 
(667,494) $
Options exercised 
(60,131) $
Options cancelled 
2,821,227  $
Outstanding at December 31, 2016 
Options exercisable as of December 31, 2016  1,506,297  $
Options vested, exercisable or expected to 
   vest as of December 31, 2016 

2,739,732  $

2.88  
13.50  
2.26  
3.60  
5.77  
50.16  
3.87  
19.08  
19.74  
66.74  
10.19  
40.89  
29.85  
14.69  

   $ 

2,488

7.9   $ 

97,832

   $ 

36,603

7.8   $ 

145,721

   $ 

46,529

7.4   $ 
6.4   $ 

123,425
87,358

29.11  

7.3   $ 

121,743  

The aggregate intrinsic value of options exercised is the difference between the estimated fair market value of 
the Company’s common stock at the date of exercise and the exercise price for in-the-money options. The aggregate 
intrinsic value of outstanding options is the difference between the closing price as of the date outstanding and the 
exercise price of the underlying stock options. The weighted-average grant-date fair value of options granted during 
the years ended December 31, 2016, 2015 and 2014 was $32.11, $25.06 and $11.33 per share, respectively. The 
total fair value of options vested during the years ended December 31, 2016, 2015 and 2014 was approximately 
$10.7 million, $5.2 million and $1.2 million, respectively, based on the grant date fair value. 

The options outstanding and vested under the Stock Plans by exercise price, at December 31, 2016, were as 

follows: 

Options Outstanding 

    Weighted Average  
Remaining 

Options Vested 

Exercise Price 
$0.96 — $1.92 
$3.60 — $3.60 
$10.08 — $38.79 
$41.83 — $54.50 
$57.89 — $97.52 
$0.96 — $97.52 

Restricted Stock Units 

Number 
  Outstanding   

  Contractual Term   Weighted Average  

Number 

(in years) 

Exercise Price 

  Exercisable 

   Weighted Average  
    Exercise Price 

141,176   
     1,030,002   
572,674   
573,030   
504,345   
     2,821,227   

2.87  $
6.01  $
7.87  $
8.67  $
9.27  $
7.35  $

141,176     $ 
1.48   
890,023     $ 
3.60   
247,046     $ 
25.89   
150,184     $ 
51.44   
77,868     $ 
71.37   
29.85    1,506,297     $ 

1.48 
3.60 
25.34 
49.67 
64.20 
14.69  

In 2015, the Company began granting restricted stock units (RSUs) under the 2014 Plan.  Holders of RSUs do 
not have stockholder rights.  Upon the release of RSUs, the Company issues new common stock from its authorized 
shares. RSUs generally vest four years from the date of grant. 

Pursuant to the 2014 Plan, the Company granted performance based RSUs to the CEO in March 2016. The 

performance based RSUs are subject to the CEO’s continued service to the Company through each applicable 

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vesting date. If a performance metric is not met within the time limits specified in the RSU agreement, the shares 
subject to vesting under the vesting tranche for that performance metric will be canceled. 

A summary of RSUs activity under the Stock Plans was as follows: 

Outstanding at December 31, 2014 
Restricted stock granted 
Restricted stock cancelled 
Outstanding at December 31, 2015 
Restricted stock granted 
Restricted stock released 
Restricted stock cancelled 
Outstanding at December 31, 2016 
Restricted stock expected to vest as of 
   December 31, 2016 

Number of   Weighted Average    Aggregate 
Grant Date 
Restricted  
Fair Value 
Stock Units  

  Intrinsic Value 
   (in thousands) 
—

—  $
5,450  $
(290) $
5,160  $
  357,479  $
(1,384) $
  (15,700) $
  345,555  $

—   $ 
56.47     
63.23     
56.09   $ 
70.31     
56.65   $ 
65.15     
70.39   $ 

348

115

25,108

  314,061   

   $ 

22,820  

The aggregate intrinsic value of RSUs released is calculated using the fair market value of the Company’s 

common stock at the date of release. The aggregate intrinsic value of outstanding RSUs is calculated based on the 
closing price of the Company’s common stock as of the date outstanding. 

2014 Employee Stock Purchase Plan 

In October 2014, the Board adopted the 2014 Employee Stock Purchase Plan (the ESPP). A total of 196,666 
shares of common stock were initially available for future issuance under the 2014 Employee Stock Purchase Plan, 
subject to an annual increase on January 1 of each year. The ESPP provides eligible employees with an opportunity 
to purchase shares of the Company’s common stock through payroll deductions of up to 15% of their eligible 
compensation, subject to plan limitations.  Under the ESPP, the purchase price of the Company stock is equal to 
85% of the lower of its fair market value at the start and end of a six-month purchase period. 

A summary of ESPP activity was as follows: 

2016 

December 31, 
2015 

2014 

Additional shares reserved 
Shares issued 
Shares available for future issuance 
Employee contributions for shares issued (in thousands) 

—  
    281,435     248,654       
    72,568     33,158       
—  
    621,029     412,162        196,666  
—   
  $

1,430     $ 

3,499   $

Early Exercises 

Stock options previously granted under the 2007 Plan allowed the Board of Directors to grant awards to 
provide employee option holders the right to elect to exercise unvested options in exchange for restricted common 
stock. Unvested shares, which amounted to 1,836 at December 31, 2016, 14,863 at December 31, 2015 and 29,613 
at December 31, 2014, were subject to a repurchase right held by the Company at the original issue price in the 
event the optionees’ employment was terminated either voluntarily or involuntarily. For exercises of employee 
options, this right lapses according to the vesting schedule designated on the associated option grant. The repurchase 
terms are considered to be a forfeiture provision. The shares purchased by the employees pursuant to the early 
exercise of stock options are not deemed to be issued or outstanding for accounting purposes until those shares vest, 
though they are legally issued and outstanding. In addition, cash received from employees for exercise of unvested 
options is treated as a refundable deposit shown as a liability on the consolidated balance sheets. As of 
December 31, 2016 and 2015 cash received related to unvested shares totaled $7,000 and $54,000, respectively. 
Amounts recorded are transferred into common stock and additional paid-in-capital as the shares vest. 

104 

 
 
  
  
  
 
 
 
 
 
 
 
  
 
 
  
 
   
     
 
 
Other 

In March 2011, the Company issued 416,983 common shares under a restricted stock agreement to one of the 

officers of the Company at a purchase price of $1.44 per share. Under the terms of the agreement, the holder was 
entitled to purchase the shares in exchange for a promissory note. All the shares were purchased in March 2011 in 
exchange for a promissory note aggregating to $0.6 million. The restricted stock agreement granted the Company 
repurchase rights which lapsed upon attainment of full vesting by the stockholder. The restricted common shares 
vested 33% one year from the vesting start date and monthly thereafter over the next two years. The note bore 
interest at 0.54% per annum compounded annually. The principal amount of the note along with accrued interest 
was discharged on a quarterly basis in arrears on a pro rata basis over a period of three years conditioned upon the 
holder continuing to provide services to the Company. The Company accounted for the grant of the restricted 
common stock as stock-based compensation based on the fair value of the shares on the original grant date, and 
recognized expense over the three-year vesting period. The Company recorded stock-based compensation expenses 
of $48,000 for the year ended December 31, 2014. At December 31, 2014, there were no shares of common stock 
subject to repurchase by the Company. 

Employee Stock-Based Compensation 

The Company estimated the fair value of stock options granted to employees and shares purchased by 
employees under the ESPP using the Black-Scholes option valuation model. The fair value is amortized on a 
straight-line basis over the requisite service period of the awards, with the exception of performance based stock 
options whose fair value is recorded as expenses when performance metrics are achieved. The following 
assumptions were used in estimating the fair value: 

2016 

Years Ended December 31, 
2015 

2014 

Stock Options: 
Expected term (in years) 
Expected volatility 
Risk-free interest rate 
Dividend Yield 
ESPP: 
Expected term (in years) 
Expected volatility 
Risk-free interest rate 
Dividend Yield 

5.3 — 6.1 

5.3 — 6.1 
  47% — 49%     46% — 59%     57% — 63%   
  1.3% — 1.9%     1.4% — 1.8%     1.7% — 2.0%  
0% 

5.3 — 6.1 

0% 

0% 

0.5 

0.5 

  46% — 53%     42% — 64%    
  0.4% — 0.6%     0.1% — 0.3%    

0% 

0% 

— 
— 
— 
— 

Expected Term. The expected term of stock-based awards represents the weighted-average period that the 
stock-based awards are expected to remain outstanding. The Company has opted to use the “simplified method” for 
estimating the expected term of the awards, whereby the expected term equals the arithmetic average of the vesting 
term and the original contractual term of the awards.  Starting in late 2016, the Company started to utilize its own 
historical data for the calculation of expected term. 

Expected Volatility. The Company determined the share price volatility for stock-based awards based on an 

analysis of the historical volatilities of a peer group of publicly traded medical device companies. In evaluating 
similarity, the Company considered factors such as industry, stage of life cycle and size. Starting in late 2016, the 
Company has started to incorporate its own stock trading volatility with those of its peer group for the calculation of 
volatility. 

Risk-Free Interest Rate. The risk-free interest rate is based on the U.S. Treasury yield in effect at the time of 
the grant for zero-coupon U.S. Treasury notes with remaining terms similar to the expected term of the stock-based 
awards. 

Dividend Rate. The expected dividend was assumed to be zero as the Company has never paid dividends and 

has no current plans to do so. 

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Expected Forfeiture Rate. The Company is required to estimate forfeitures at the time of grant, and revise 

those estimates in subsequent periods if actual forfeitures differ from those estimates. The Company uses historical 
data to estimate pre-vesting option forfeitures and record stock-based compensation expense only for those awards 
that are expected to vest. To the extent actual forfeitures differ from the estimates, the difference will be recorded as 
a cumulative adjustment in the period that the estimates are revised. 

The Company accounts for RSUs at their fair value, based on the closing market price of the Company’s 
common stock on the grant date. The fair value is amortized on a straight-line basis over the requisite service period 
of the awards, with the exception of performance based awards whose fair value is recorded as an expense when 
performance metrics are achieved. 

A summary of pre-tax stock-based compensation expense by line items in the consolidated statements of 

operations was as follows (in thousands): 

Years Ended December 31, 
2015 

2014 

2016 

Cost of revenue 
Research and development 
Sales, general and administrative 

Total stock-based compensation expense 

 $

  $

1,094   $
3,182    
11,484    
15,760   $

621     $ 
1,401       
5,303       
7,325     $ 

147  
661  
1,190  
1,998   

The effect of recording pre-tax stock-based compensation expense recognized were as follows (in thousands): 

Stock options 
Restricted stock units 
Employee stock purchase plan 

Total stock-based compensation expense 

 $

  $

Years Ended December 31, 
2015 

2014 

2016 
10,832   $
3,548    
1,380    
15,760   $

6,679     $ 
9       
637       
7,325     $ 

1,998  
—  
—  
1,998   

As of December 31, 2016, total stock-based compensation expense not yet recognized, net of estimated 

forfeitures, were as follows: 

Stock options 
Restricted stock units 
Employee stock purchase plan 

Unrecognized Weighted-Average   
Compensation Amortization Period  
(in thousands)
$

(in years) 

25,602  
18,253  
757  

2.5  
3.3  
0.4   

9. Income Taxes 

The components of the Company’s income (loss) before income taxes were as follows: 

2016 

Years Ended December 31, 
2015 
(in thousands) 
  $ (34,258)  $ (68,919 )   $  (31,807 )
1,605  
  $ (30,155)  $ (66,265 )   $  (30,202 )

2,654       

4,103     

2014 

Domestic 
Foreign 

Total income (loss) before income taxes 

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The components of income tax expense are as follows (in thousands): 

Years Ended December 31, 
2015 

2014 

2016 

Current: 

Federal 
State 
Foreign 

Total current 

Deferred: 

Federal 
State 
Foreign 

Total deferred 

  $

—   $
181    
1,442    
1,623    

—     $ 
34       
1,132       
1,166       

—    
—    
—    
—    

—       
—       
—       
—       

—  
2  
476  
478  

—  
—  
—  
—  

Total income tax expense 

  $

1,623   $

1,166     $ 

478   

Income tax expense differs from the amount computed by applying the statutory federal income tax rate as 

follows: 

Years Ended December 31, 
2015 

2014 

2016 

Tax at statutory federal rate 
State tax, net of federal benefit 
Other 
Foreign rate differential 
Tax credits 
Change in valuation allowance 

Total 

34.0%  
(0.4)% 
(3.7)% 
(0.2)% 
3.2%  
(38.4)% 
(5.5)% 

34.0%     
0.0%     
(3.5)%    
(0.5)%    
1.6%     
(33.4)%    
(1.8)%    

34.0 % 
0.0 % 
(5.3 )%
0.2 % 
2.0 % 
(32.5 )%
(1.6 )%

The tax effects of temporary differences and carryforwards that give rise to significant portions of deferred tax 

assets are as follows: 

Net operating loss carryforwards 
Tax credits 
Depreciation 
Stock-based compensation 
Accruals and reserves 
Other 

Deferred tax assets 

Other 

Deferred tax liabilities 

Valuation allowance 

  $

December 31, 

2016 

2015 

(in thousands) 

60,610    $ 
7,655      
26      
5,207      
7,559      
4,671      
85,728      

56,340  
5,236  
13  
1,857  
3,617  
313  
67,376  

—      
—      

(345 )
(345 )

(85,728)     

(67,031 )

Net deferred tax assets 

  $

—    $ 

—   

The Company has established a full valuation allowance against its deferred tax assets due to the uncertainty 

surrounding realization of these assets. 

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 Realization of deferred tax assets is dependent upon future earnings, if any, the timing and amount of which 

are uncertain. Accordingly, the net deferred tax assets have been fully offset by a valuation allowance. The valuation 
allowance increased by $18.7 million, $23.4 million and $9.4 million for the years ended December 31, 2016, 2015 
and 2014, respectively. 

As of December 31, 2016, the Company had net operating loss carryforwards (NOLs) for federal and state 
income tax purposes of approximately $224.7 million and $77.3 million, respectively. These federal and state NOLs 
include excess tax benefit related to stock-based compensation in the amount of $54.8 million and $23.7 million, 
respectively. The excess tax benefit reflected in the Company’s net operating loss carryforwards will be accounted 
for as a credit to stockholders’ equity, if and when realized, under current accounting. In determining if and when 
excess tax benefits have been realized, the Company has elected to utilize the with-and-without approach with 
respect to such excess tax benefits.  The federal NOLs begin expiring in 2026, and the state NOLs begin expiring in 
2017. 

As of December 31, 2016, the Company had research and development credit carryforwards of approximately 

$5.8 million and $5.1 million for federal and California state income tax purposes, respectively. The federal credit 
carryforward begins expiring in 2026, and the state credits carry forward indefinitely. 

Under Section 382 of the Internal Revenue Code of 1986, as amended, the Company’s ability to utilize NOLs 

or other tax attributes such as research tax credits, in any taxable year may be limited if the Company experiences, 
or has experienced, an “ownership change.” A Section 382 “ownership change” generally occurs if one or more 
stockholders or groups of stockholders, who own at least 5% of the Company’s stock, increase their ownership by 
more than 50 percentage points over their lowest ownership percentage within a rolling three-year period. Similar 
rules may apply under state tax laws. As a result of the Company’s June 2015 underwritten public offering, the 
Company experienced a Section 382 “ownership change.”  The Company currently estimates that this “ownership 
change” will not inhibit its ability to utilize its NOLs. The Company may, in the future, experience one or more 
additional Section 382 “ownership changes.” If so, the Company may not be able to utilize a material portion of its 
NOLs and tax credits, even if the Company achieves profitability. 

The earnings of the Company's foreign subsidiaries are not considered indefinitely reinvested. As a result, the 
Company has provided for residual U.S. tax on its foreign subsidiary unremitted earnings net of a foreign tax credit 
deferred tax asset as of December 31, 2016. The net amount of deferred tax liability is considered 
insignificant.   The timing of the potential remittance of these earning is uncertain at December 31, 2016. 

The Company had unrecognized tax benefits (UTBs) of approximately $3.4 million as of December 31, 2016. 

All of the deferred tax assets associated with these UTBs are fully offset by a valuation allowance. The following 
table summarizes the activity related to UTBs (in thousands): 

Balance at December 31, 2013 
Increases related to current year tax provisions 
Increases related to prior year tax provisions 
Balance at December 31, 2014 
Increases related to current year tax provisions 
Increases related to prior year tax provisions 
Balance at December 31, 2015 
Increases related to current year tax provisions 
Decreases related to prior year tax provisions 
Balance at December 31, 2016 

  $

  $

1,065   
220   
677   
1,962   
813   
1,069   
3,844   
1,059   
(1,519 ) 
3,384   

All of these UTBs, if recognized, would affect the effective tax rate before consideration of the valuation 

allowance. 

In accordance with ASC 740, Income Taxes, the Company is classifying interest and penalties as a component 

of tax expense. There were no interest or penalties accrued at December 31, 2016, December 31, 2015, and 
December 31, 2014. 

108 

 
 
   
   
   
   
   
   
   
   
 
The Company files U.S. federal and state income tax and foreign income tax returns with varying statues of 
limitations. The Company’s tax years from inception in 2006 will remain open to examination due to the carryover 
of the unused NOLs and tax credits. The Company does not have any tax audits or other proceedings pending. 

The Company does not expect any material changes to the estimated amount of liability associated with its 

uncertain tax positions within the next twelve months. 

10. Net Loss Per Share Attributable to Common Stockholders 

The following table summarizes the computation of basic and diluted net loss per share attributable to 

common stockholders of the Company (in thousands, except share and per share data): 

$

Net loss 
Accretion of convertible preferred stock to 
   redemption value 
Net loss attributable to common stockholders, basic
   and diluted 
Weighted average shares outstanding 
Less: weighted average shares subject to repurchase  
Weighted average shares used to compute basic and
   diluted net loss per share 
Net loss per share attributable to common 
   stockholders, basic and diluted 

Years Ended December 31, 
2015 
(67,431 )  $ 

2016 
(31,778) $

2014 
(30,680 )

—   

—      

(147 )

(31,778) $

(67,431 )  $ 

$
(30,827 )
  28,492,091    26,603,512      4,486,569  
(45,906 )

(21,622 )    

(7,088)  

  28,485,003    26,581,890      4,440,663  

$

(1.12) $

(2.54 )  $ 

(6.94 )

Basic net loss per share attributable to common stockholders is computed by dividing the net loss attributable 
to common stockholders by the weighted-average number of common shares outstanding for the period. Diluted net 
loss per share attributable to common stockholders is computed by dividing the net loss attributable to common 
stockholders by the weighted-average number of common shares and potentially dilutive securities outstanding for 
the period, determined using the treasury-stock method and the as-if converted method, for convertible securities, if 
inclusion of these is dilutive. Because the Company has reported a net loss for all periods presented, diluted net loss 
per common share is the same as basic net loss per common share for those periods. 

The following potentially dilutive securities outstanding at the end of the periods presented have been 

excluded from the computation of diluted shares outstanding: 

Unreleased restricted stock 
Options to purchase common stock 

Total 

December 31, 
2015 

2016 
    345,555     
—  
    2,821,227      3,050,288       2,973,732  
    3,166,782      3,055,448       2,973,732   

5,160       

2014 

Additionally, since the Company expects to settle the principal amount of its outstanding convertible senior 

notes in cash, the Company uses the treasury stock method for calculating any potential dilutive effect of the 
conversion spread on diluted net income per share, if applicable. The conversion spread will have a dilutive impact 
on diluted net income per share of common stock when the average market price of the Company’s common stock 
for a given period exceeds the conversion price of $96.37 per share for the 2021 Notes, which has not occurred as of 
December 31, 2016. 

11. Employee Benefit Plan. 

In 2007, the Company adopted a 401(K) plan for its employees whereby eligible employees may contribute up 
to the maximum amount permitted by the Internal Revenue Code of 1986, as amended.  In June 2016, the Company 

109 

 
 
  
  
  
  
  
  
 
   
  
 
 
 
  
 
 
  
 
   
     
 
 
adopted a policy to match a portion of employee contributions for all qualified employees participating in the 401(k) 
plan.  For the year ended December 31, 2016, the Company recorded expense of $1.3 million for matching 
contributions. 

12. Selected Quarterly Financial Information (Unaudited) 

Three Months Ended 

  December 31,   September 30,  

2016 

2016 

June 30, 
2016 

    March 31, 

2016 

Total revenue 
Gross profit 
Loss from operations 
Net loss 
Net loss attributable to common stockholders, 
   basic and diluted 
Net loss per share attributable to common 
   stockholders, basic and diluted 
Shares used in computing net loss per common 
   share, basic and diluted 

Total revenue 
Gross profit 
Loss from operations 
Net loss 
Net loss attributable to common stockholders, 
   basic and diluted 
Net loss per share attributable to common 
   stockholders, basic and diluted 
Shares used in computing net loss per common 
   share, basic and diluted 

(in thousands, except per share data) 
55,400    $ 
36,558    $ 
(5,923 )  $ 
(8,779 )  $ 

60,922  $
41,687  $
(1,872) $
(3,886) $

70,531  $
48,839  $
(6,269) $
(9,825) $

41,651 
25,987 
(9,017)
(9,288)

(9,825) $

(3,886) $

(8,779 )  $ 

(9,288)

(0.34) $

(0.14) $

(0.31 )  $ 

(0.33)

 $
 $
 $
 $

 $

 $

   28,817,333    28,542,760    28,381,253      28,194,457  

Three Months Ended 

December 31,   September 30,  

2015 

2015 

June 30, 
2015 

    March 31, 

2015 

(in thousands, except per share data) 
11,418    $ 
5,910    $ 
(19,175 )  $ 
(19,726 )  $ 

15,402  $
9,434  $
(17,709) $
(19,454) $

33,124  $
20,353  $
(13,144) $
(14,191) $

9,662 
5,789 
(12,339)
(14,060)

(14,191) $

(19,454) $

(19,726 )  $ 

(14,060)

(0.51) $

(0.70) $

(0.77 )  $ 

(0.57)

$
$
$
$

$

$

  28,003,957    27,861,523    25,564,249      24,849,229  

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ITEM 9. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND 
FINANCIAL DISCLOSURE 

None. 

ITEM 9A. CONTROLS AND PROCEDURES 

Evaluation of Disclosure Controls and Procedures 

The term “disclosure controls and procedures,” as defined in Rules 13a-15(e) and 15d-15(e) under the 

Securities Exchange Act of 1934, as amended (the Exchange Act) refers to controls and procedures that are designed 
to provide reasonable assurance that information required to be disclosed by a company in the reports that it files or 
submits under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified 
in the SEC’s rules and forms. Disclosure controls and procedures include, without limitation, controls and 
procedures designed to ensure that information required to be disclosed by a company in the reports that it files or 
submits under the Exchange Act is accumulated and communicated to the company’s management, including its 
principal executive and principal financial officers, or persons performing similar functions, as appropriate to allow 
timely decisions regarding required disclosure. Our management recognizes that any controls and procedures, no 
matter how well designed and operated, can provide only reasonable assurance of achieving their objectives and our 
management necessarily applies its judgment in evaluating the cost-benefit relationship of possible controls and 
procedures. Our disclosure controls and procedures are designed to provide reasonable assurance of achieving their 
control objectives. 

Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, has 
evaluated the effectiveness of our disclosure controls and procedures as of December 31, 2016, the end of the period 
covered by this Annual Report. Based upon such evaluation, our Chief Executive Officer and Chief Financial 
Officer have concluded that our disclosure controls and procedures were effective at the reasonable assurance level 
as of such date. 

Management’s Annual Report on Internal Control Over Financial Reporting 

Our management is responsible for establishing and maintaining adequate internal control over financial 

reporting. Internal control over financial reporting is a process designed by, or under the supervision of, our Chief 
Executive Officer and Chief Financial Officer, and effected by our Board of Directors, management and other 
personnel, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of 
financial statements for external purposes in accordance with generally accepted accounting principles and includes 
those policies and procedures that: 

 

 

 

Pertain to the maintenance of records that accurately and fairly reflect in reasonable detail the 
transactions and dispositions of the assets of our company; 

Provide reasonable assurance that transactions are recorded as necessary to permit preparation of 
financial statements in accordance with generally accepted accounting principles, and that our receipts 
and expenditures are being made only in accordance with authorizations of our management and 
directors; and 

Provide reasonable assurances regarding prevention or timely detection of unauthorized acquisition, use 
or disposition of our assets that could have a material adverse effect on our financial statements. 

Our management assessed our internal control over financial reporting as of December 31, 2016, the end the 

period covered by this Annual Report. Management based its assessment on criteria established in “Internal 
Control—Integrated Framework (2013)” issued by the Committee of Sponsoring Organizations of the Treadway 
Commission. Based on management's assessment of our internal control over financial reporting, management 
concluded that, as of December 31, 2016, our internal control over financial reporting was effective. 

Internal control over financial reporting has inherent limitations. Internal control over financial reporting is a 

process that involves human diligence and compliance and is subject to lapses in judgment and breakdowns 
resulting from human failures. Internal control over financial reporting also can be circumvented by collusion or 

111 

 
improper management override. Because of such limitations, there is a risk that material misstatements will not be 
prevented or detected on a timely basis by internal control over financial reporting. However, these inherent 
limitations are known features of the financial reporting process. Therefore, it is possible to design into the process 
safeguards to reduce, though not eliminate, this risk. 

The effectiveness of the Company’s internal control over financial reporting as of December 31, 2016 has 

been audited by PricewaterhouseCoopers LLP, an independent registered public accounting firm, as stated in their 
report which appears in Part II, Item 8 of this Annual Report. 

Changes in Internal Control over Financial Reporting 

There was no change in our internal control over financial reporting that occurred during the most recent fiscal 

quarter covered by this Annual Report that has materially affected, or is reasonably likely to materially affect, our 
internal control over financial reporting. 

ITEM 9B. OTHER INFORMATION 

None. 

112 

 
PART III 

ITEM 10. DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE 

Executive Officers, Significant Employee and Non-Employee Directors of the Registrant 

The following table sets forth information regarding our executive officers, significant employees and 

directors, as of February 1, 2017: 

Name 
Executive Officers 
Rami Elghandour 
Andrew H. Galligan 
Doug Alleavitch 
Christopher Christoforou 
Michael Enxing 
Patrick Schmitz 
Significant Employees 
David Caraway, M.D., Ph.D. 
Richard B. Carter 
Bradford E. Gliner 
Michael W. Hall 
Neeraj Teotia 
Non-Employee Directors 
Michael DeMane 
Ali Behbahani, M.D.(2)(3) 
Lisa D. Earnhardt(1)(3) 
Frank Fischer(3) 
Wilfred E. Jaeger, M.D.(1)(2) 
Shawn T McCormick(1) 
Brad Vale, Ph.D., D.V.M.(2) 

Age 

Position(s) 

38 President and Chief Executive Officer 
60 Chief Financial Officer 
56 Vice President, Quality and Operations 
47 Vice President, Research and Development 
50 Vice President of Sales 
57 Vice President, Operations 

60 Chief Medical Officer 
46 Vice President of Finance, Corporate Controller 
51 Vice President, Clinical & Regulatory Affairs 
68 General Counsel 
42 Vice President, Marketing 

60 Chairman of the Board 
40 Director 
47 Director 
75 Director 
61 Director 
52 Director 
64 Director 

(1)  Member of the audit committee. 

(2)  Member of the compensation committee. 

(3)  Member of the nominating and corporate governance committee. 

Executive Officers 

Rami Elghandour joined us in October 2012, has served as our Chief Business Officer and currently serves 

as our President and Chief Executive Officer. From September 2008 to October 2012, Mr. Elghandour managed 
investments for Johnson & Johnson Development Corporation, or JJDC, where he led several investments and 
served on the board of directors of a number of private companies, including our board of directors. Additionally, he 
led strategic initiatives in the development and management of JJDC’s portfolio. From 2001 to 2006, 
Mr. Elghandour worked for Advanced Neuromodulation Systems, Inc. (acquired by St. Jude Medical), a medical 
device company, where he led firmware design and development on several implantable neurostimulators. 
Mr. Elghandour received an M.B.A. from the Wharton School of the University of Pennsylvania and a B.S. in 
Electrical and Computer Engineering from Rutgers University School of Engineering. 

Andrew H. Galligan has served as our Chief Financial Officer since May 2010. From February 2009 to July 

2010, Mr. Galligan served as Vice President of Finance and Chief Financial Officer at Ooma, a consumer 
electronics manufacturer and VOIP service provider. From 2007 to 2008, Mr. Galligan served as Vice President of 
Finance and CFO of Reliant Technologies, Inc. (later acquired by Solta Medical, Inc.), a medical device company. 
Mr. Galligan has also held the top financial executive position at several other medical device companies and began 
his career in various financial positions at KPMG and Raychem Corp. Mr. Galligan served on the board of directors 
of DiaDexus, Inc., a public medical diagnostics company, until January 2015. Mr. Galligan received a degree in 

113 

 
 
  
  
  
 
Business Studies from Trinity College in Dublin, Ireland and is also a Fellow of the Institute of Chartered 
Accountants in Ireland. 

Doug Alleavitch has served as our Vice President, Quality since April 2015.  From October 2009 to April 

2015, Mr. Alleavitch served as Vice President, Operations and Quality Assurance at AEGEA Medical, Inc., a 
medical device company, where he oversaw manufacturing and quality assurance procedures. From August 2007 to 
September 2009, Mr. Alleavitch served first as Senior Director, Manufacturing and later as Vice President, 
Operations at AngioScore, Inc., a medical device company, where he oversaw AngioScore’s production, supply 
chain management and manufacturing engineering. From February 2002 to July 2007, Mr. Alleavitch served first as 
Director, Quality Assurance and later as Director, Operations at Boston Scientific, a medical device company. Mr. 
Alleavitch received a BS in Chemical Engineering from Cornell University, an M.S. in Industrial Engineering, and 
an M.B.A. from the University of Illinois, and an M.S. in Chemical Engineering from the Illinois Institute of 
Technology. 

Christofer Christoforou has served as our Vice President, Research and Development since July 2016. From 

December 2014 to July 2016, Mr. Christoforou served as Vice President, Quality Engineering at Thoratec 
Corporation, a medical device company where he oversaw the operational, design and supplier quality engineering 
functions. From October 1999 to December 2014, Mr. Christoforou served in several leadership positions of 
increasing levels of responsibility at Thoratec Corporation. From August 1993 to February 1999, Mr. Christoforou 
served as a Manager of Engineering and various Engineering positions for United States Surgical Corporation, a 
producer of tools for use in surgery. Mr. Christoforou received a B.S. in Biomedical Engineering from Boston 
University and a MS in Biomedical Engineering from The Johns Hopkins University in Maryland. 

Michael Enxing has served as our Vice President of Sales since December 2012. From 2009 to December 

2012, Mr. Enxing served as Vice President of Vertos Medical Inc., a medical device company. From 1990 to 2009, 
Mr. Enxing held various executive positions at Cardiovascular Systems, Inc. (f/k/a Cardio Vascular Solutions 
(CSI)), a medical device company, Advanced Neuromodulation Systems, Inc. (acquired by St. Jude Medical), a 
medical device company, Stryker Corporation, a medical technology company, and Tecnol Medical Products, Inc. 
(acquired by Kimberly Clark), a medical device company. Mr. Enxing is a graduate of Iowa State University with a 
B.S. in Communications and focus in business administration. 

Patrick Schmitz has served as our Vice President, Operations since March 2016. From 2005 to October 2015, 

Mr. Schmitz served as Vice President, Operations at Thoratec Corporation, a medical device company, where he 
oversaw all domestic and international operations. From 2003 to 2005, Mr. Schmitz served as Vice President, North 
American Operations at GN ReSound, a medical device company. Mr. Schmitz also held several leadership 
positions in increasing levels of responsibility at St. Jude from 1993 to 2003. Mr. Schmitz holds a B.S. in Industrial 
Technology from the University of Wisconsin – Stout. 

Significant Employees 

David Caraway, M.D., Ph.D. has served as our Chief Medical Officer since April 2014. Before joining 
Nevro, from 2001 to May 2014, Dr. Caraway was the CEO of The Center for Pain Relief, Tri-State, L.L.C., in 
partnership with St. Mary’s Regional Medical Center in Huntington, West Virginia. Dr. Caraway has maintained an 
active medical practice for over 20 years and has held leadership positions in the North American Neuromodulation 
and the American Society of Interventional Pain Physicians. As a nationally recognized expert in the treatment of 
chronic pain, he has lectured regionally, nationally and internationally in the field of Interventional Pain Medicine 
and authored numerous publications in this field. Dr. Caraway received a B.S. in chemical engineering from the 
University of Virginia School of Engineering, an M.D. from the University of Virginia School of Medicine and a 
Ph.D. in biophysics from the University of Virginia Graduate School of Arts and Sciences. He also received post-
graduate training in anesthesiology and pain management from the University of Virginia. Dr. Caraway is board 
certified by the American Board of Anesthesiology. 

Richard B. Carter has served as our Vice President of Finance, Corporate Controller since November 2015, 
having held roles of increasing responsibility in finance and accounting since joining Nevro as Corporate Controller 
in September 2014.  From October 2013 to October 2014, Mr. Carter served as Corporate Controller at ClearEdge 
Power, Inc., a privately held fuel cell manufacturing company.  From December 2011 to October 2013, Mr. Carter 

114 

 
served as the Vice President of Finance and Corporate Controller at Kovio, Inc., a privately held electronic device 
manufacturing company.  From March 2007 to December 2011, Mr. Carter served as Vice President of Finance and 
Corporate Controller at MiaSolé, a thin-film solar panel manufacturer.  Previously, Mr. Carter served as the 
Corporate Controller at PortalPlayer, Inc. and Transmeta Corporation, both publicly traded fabless semiconductor 
companies.  Mr. Carter received a  B.S. in Business Administration from California State University, Chico.  Mr. 
Carter is a Certified Public Accountant (inactive license) and began his career as an auditor at Ernst & Young, LLP. 

Bradford E. Gliner has served as our Vice President of Clinical and Regulatory Affairs since May 2011. 

From 2008 to May 2011, Mr. Gliner was President and CEO at MitoGuard Neuroscience, Inc., a 
photobiomodulation medical device company. From 1999 to 2008, Mr. Gliner was Vice President of Research at 
Northstar Neuroscience, Inc., a medical device company, where he led research on numerous neuromodulation 
applications. From 1992 to 1999, Mr. Gliner was also a co-founder of Heartstream, Inc. (acquired by Koninklijke 
Philips Electronics NV), a medical device company that manufactures and markets automatic external defibrillators. 
Mr. Gliner received a B.S. in Electrical Engineering from the University of Illinois and a M.S. in Biomedical 
Engineering from Johns Hopkins University in Maryland. 

Michael Hall has served as our General Counsel since January 2015. He was a partner at Latham & Watkins 

from February 1999 to December 2014. Mr. Hall practiced for a number of years at Wilson, Sonsini, Goodrich & 
Rosati and was a co-founder of Venture Law Group prior to joining Latham & Watkins. His practice was focused on 
representation of life science companies primarily in the medical device industry. He also represented underwriters 
and venture capital firms in both public and private financing transactions. He is a member of the board of San 
Francisco RBI, a non-profit focused on sports and literacy for underprivileged children in San Francisco. Mr. Hall 
received a B.A. from California University, Sonoma and a J.D. from the University of California at Berkley, School 
of Law (Boalt Hall). 

Neeraj Teotia has served as our Vice President of Marketing since May 2016, having held roles of increasing 
responsibility in marketing since joining Nevro as Director, Marketing in April 2014. From July 2012 to April 2014 
Mr. Teotia served as a Director, New Business Development in the Global Surgery Group at Johnson & Johnson 
where he was responsible for assessing various licensing and acquisition opportunities. Prior to his role in New 
Business Development, Mr. Teotia worked in various marketing, licensing & acquisitions and research & 
development roles within the medical device group at Johnson & Johnson. Mr. Teotia received a MBA from the 
Kellogg School of Management at Northwestern University and holds a B.S. in Electrical Engineering from the 
University of Illinois at Urbana-Champaign. 

Non-Employee Directors 

Michael DeMane joined us in March 2011, has served as our Chief Executive Officer and as Executive 

Chairman.  Effective January 1, 2017, Mr. DeMane transitioned to non-executive Chairman of the Board. 
Mr. DeMane has served on the board of directors of several private companies since 2009, as well as on the board of 
directors of eReserach Technology, Inc., a public company specializing in contract research clinical services, from 
July 2008 to April 2012. From March 2009 to June 2010, Mr. DeMane served as a Senior Advisor to Thomas, 
McNerney & Partners, a healthcare venture firm. Mr. DeMane served as the Chief Operating Officer of 
Medtronic, Inc. from August 2007 to April 2008. Prior to his COO role, Mr. DeMane served at Medtronic Inc. as 
Senior Vice President from May 2007 to August 2007, Senior Vice President and President: Europe, Canada, Latin 
America and Emerging Markets from August 2005 to May 2007, Senior Vice President and President: Spinal, ENT 
and Navigation from February 2002 to August 2005, and President, Spinal from January 2000 to February 2002. 
Prior to that, he was President at Interbody Technologies, a division of Medtronic Sofamor Danek, Inc., from June 
1998 to December 1999. From April 1996 to June 1998, Mr. DeMane served at Smith & Nephew Pty. Ltd. as 
Managing Director, Australia and New Zealand, after a series of research and development and general management 
positions with Smith & Nephew Inc. Mr. DeMane earned a B.S. in Chemistry from St. Lawrence University and an 
M.S. in Bioengineering from Clemson University. We believe that Mr. DeMane is qualified to serve on our board of 
directors due to his investment experience, strategic leadership track record, service on other boards of directors of 
companies in the healthcare industry and his service as our chief executive officer. 

Ali Behbahani, M.D. has served on our board of directors since September 2014. Dr. Behbahani joined New 

Enterprise Associates, Inc., or NEA, in 2007 and is a Partner on the healthcare team. Prior to joining NEA, 

115 

 
Dr. Behbahani worked as a consultant in business development at The Medicines Company, a specialty 
pharmaceutical company developing acute care cardiovascular products. Dr. Behbahani previously held positions as 
a venture associate at Morgan Stanley Venture Partners and as a healthcare investment banking analyst at Lehman 
Brothers. He conducted basic science research in the fields of viral fusion inhibition and structural proteomics at the 
National Institutes of Health and at Duke University. Dr. Behbahani currently serves on the board of directors of 
several private companies. Dr. Behbahani has also been a director of Adaptimmune Therapeutics plc, a public 
biopharmaceutical company, since September 2014, and serves on the nominating and governance committee. 
Dr. Behbahani holds an M.D. from The University of Pennsylvania School of Medicine, an M.B.A. from The 
University of Pennsylvania Wharton School and a B.A. in Biomedical Engineering, Electrical Engineering and 
Chemistry from Duke University. We believe that Dr. Behbahani is qualified to serve on our board of directors due 
to his experience in the life science industry and his investment experience. 

Lisa D. Earnhardt has served on our Board since June 2015.  She has served as President and Chief 
Executive Officer of Intersect ENT and as a member of its board of directors since March 2008. Prior to joining 
Intersect ENT, Ms. Earnhardt served as President of Boston Scientific’s Cardiac Surgery division (formerly known 
as Guidant Corporation, or Guidant) from June 2006 to January 2008 until its sale to Getinge Group. From August 
1996 to April 2006, Ms. Earnhardt worked at Guidant in a variety of sales and marketing leadership positions. Ms. 
Earnhardt served on the board of directors of Kensey Nash, a publicly traded company from 2011 until it was 
acquired by Royal DSM NA in 2012, where she served on the board’s nominating and governance and audit 
committees. Ms. Earnhardt holds an M.B.A. from Northwestern’s Kellogg School of Management and a B.S. in 
Industrial Engineering from Stanford University. We believe that Ms. Earnhardt is qualified to serve on our board of 
directors due to her experience in the medical device industry. 

Frank Fischer has served on our board of directors since October 2012. Mr. Fischer joined NeuroPace, Inc., a 
privately held developer of treatment devices for neurological disorders, in 2000 and currently serves as its President 
and Chief Executive Officer. From May 1998 to September 1999, Mr. Fischer was President, Chief Executive 
Officer and a director of Heartport, Inc., a formerly publicly traded cardiac surgery company (later acquired by 
Johnson & Johnson in 2001). From 1987 to 1997, Mr. Fischer served as President and Chief Executive Officer of 
Ventritex, Inc., a publicly traded designer, developer, manufacturer and marketer of implantable defibrillators and 
related products for the treatment of ventricular tachycardia and ventricular fibrillation, which was acquired by 
St. Jude Medical in 1997. Mr. Fischer currently serves on the board of directors of several privately held companies. 
Mr. Fischer received a B.S. in Mechanical Engineering and a M.S. in Management from Rensselaer Polytechnic 
Institute. We believe that Mr. Fischer is qualified to serve on our board of directors due to his operational experience 
in the life science industry. 

Wilfred E. Jaeger, M.D. has served on our board of directors since January 2012. Dr. Jaeger cofounded 

Three Arch Partners in 1993 and has served as a Partner and Managing Member since that time. Prior to co-
founding Three Arch Partners, Dr. Jaeger was a general partner at Schroder Ventures. Dr. Jaeger currently serves on 
the board of directors of Concert Pharmaceuticals, Inc., a public clinical stage biopharmaceutical company, 
Threshold Pharmaceuticals, Inc., a public pharmaceutical company, as well as numerous private companies. 
Dr. Jaeger received a B.S. in Biology from the University of British Columbia, an M.D. from the University of 
British Columbia School of Medicine and an M.B.A from the Stanford Graduate School of Business. We believe 
that Dr. Jaeger is qualified to serve on our board of directors due to his investment experience, strategic leadership 
track record and service on other boards of directors of life sciences companies. 

Shawn T McCormick has served on our board of directors since September 2014. Mr. McCormick served as 

Chief Financial Officer of Tornier N.V., a public medical device company, from September 2012 to October 2015 
when Tornier merged with Wright Medical Group. From April 2011 to February 2012, Mr. McCormick was Chief 
Operating Officer of Lutonix, Inc., a medical device company acquired by C. R. Bard, Inc. in December 2011. From 
January 2009 to July 2010, Mr. McCormick served as Senior Vice President and Chief Financial Officer of ev3 Inc., 
a public endovascular device company acquired by Covidien plc in July 2010. From May 2008 to January 2009, 
Mr. McCormick served as Vice President, Corporate Development at Medtronic, Inc., a public medical device 
company, where he was responsible for leading Medtronic’s worldwide business development activities. From 2007 
to 2008, Mr. McCormick served as Vice President, Corporate Technology and New Ventures of Medtronic. From 
2002 to 2007, Mr. McCormick was Vice President, Finance for Medtronic’s Spinal, Biologics and Navigation 
business. Prior to that, Mr. McCormick held various other positions with Medtronic, including Corporate 

116 

 
Development Director, Principal Corporate Development Associate, Manager, Financial Analysis, Senior Financial 
Analyst and Senior Auditor. Prior to joining Medtronic, he spent four years with the public accounting firm KPMG 
Peat Marwick. He has been a director of Entellus Medical, Inc., a public medical device company, since November 
2014, and serves as the chairman of the audit committee and as a member of the nominating and corporate 
governance committee. Mr. McCormick has been a director of SurModics, Inc., a public medical device and in vitro 
diagnostic technologies company, since December 2015 and serves on the audit committee and corporate 
governance and nominating committee.  Mr. McCormick earned his M.B.A. from the University of Minnesota’s 
Carlson School of Management and his B.S. in Accounting from Arizona State University. He is a Certified Public 
Accountant (inactive license). We believe that Mr. McCormick is qualified to serve on our board of directors due to 
his financial expertise and operational experience in the medical device industry. 

Brad Vale, Ph.D., D.V.M., has served on our board of directors since March 2015. Dr. Vale was Head of 

Johnson & Johnson Development Company, or JJDC, from January 2012 to March 2015. Dr. Vale joined JJDC in 
March 1992, and in April 2008, was appointed to the position of Vice President, Head of Venture Investments. From 
September 1989 to March 1992, Dr. Vale supported Johnson & Johnson’s medical device businesses at the 
Corporate Office of Science and Technology as an Executive Director. From 1982 to 1989, he was at Ethicon, Inc., 
a Johnson & Johnson subsidiary, working on preclinical studies, new business development, and a coronary artery 
bypass graft internal venture. Dr. Vale currently serves or has served on the board of directors of several private 
companies. Dr. Vale holds a Ph.D. from Iowa State University, a D.V.M. from Washington State University and a 
B.S. in Chemistry and Biology from Beloit College. We believe that Dr. Vale is qualified to serve on our board of 
directors due to his investment experience and strategic leadership in the life sciences industry. 

The remaining information required by this Item 10 is hereby incorporated by reference from the information 
under the captions “Corporate Governance” and “Section 16(a) Beneficial Ownership Reporting Compliance” that 
will be contained in the Proxy Statement for our 2017 Annual Meeting of Stockholders (or the Proxy Statement). 

We have adopted a written code of conduct and ethics that applies to our principal executive officer, principal 
financial officer, principal accounting officer or controller, or persons serving similar functions. The text of our code 
of business conduct and ethics has been posted on our website at http://www.nevro.com. 

ITEM 11. EXECUTIVE COMPENSATION 

The information required by this Item 11 is incorporated by reference from the information under the captions 

“Director Compensation,” “Executive Compensation” and “Corporate Governance” that will be contained in the 
Proxy Statement. 

ITEM 12. SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND 
RELATED STOCKHOLDER MATTERS 

The information required by this Item 12 is incorporated by reference from the information under the captions 
“Equity Compensation Plan Information” and “Security Ownership of Certain Beneficial Owners and Management” 
that will be contained in the Proxy Statement. 

ITEM 13. CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR 
INDEPENDENCE 

The information required by this Item 13 is incorporated by reference from the information under the captions 

“Certain Relationships and Related Transactions” and “Corporate Governance” that will be contained in the Proxy 
Statement. 

ITEM 14. PRINCIPAL ACCOUNTANT FEES AND SERVICES 

The information required by this Item 14 is incorporated by reference from the information under the caption 

“Ratification of Appointment of Independent Registered Public Accounting Firm” that will be contained in the 
Proxy Statement. 

117 

 
ITEM 15. EXHIBITS and FINANCIAL STATEMENT SCHEDULES 

(a)The following documents are filed as part of this Annual Report: 

PART IV 

1. 

Consolidated Financial Statements: 

Reference is made to the Index to consolidated financial statements of Nevro Corp. under Item 8 of Part II hereof. 

2. 

Financial Statement Schedule: 

All schedules are omitted because they are not applicable or the amounts are immaterial or the required information 
is presented in the consolidated financial statements and notes thereto in Part II, Item 8 above. 

3. 

Exhibits 

See Exhibit Index immediately following the signature page of this Form 10-K. 

ITEM 16. FORM 10-K SUMMARY 

None. 

118 

 
 
Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, as amended the 

registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized. 

SIGNATURES 

February 23, 2017: 

NEVRO CORP. 

By: 

  /s/ Rami Elghandour 
  Rami Elghandour 
President and Chief Executive Officer 

POWER OF ATTORNEY 

KNOW ALL PERSONS BY THESE PRESENTS, that each person whose signature appears below constitutes and 
appoints each of Rami Elghandour and Andrew H. Galligan his or her true and lawful attorney-in-fact and agent, 
with full power of substitution, for him or her and in his or her name, place and stead, in any and all capacities, to 
sign any and all amendments to this Annual Report on Form 10-K, and to file the same, with all exhibits thereto, and 
other documents in connection therewith, with the Securities and Exchange Commission, granting unto said 
attorney-in-fact and agent, full power and authority to do and perform each and every act and thing requisite and 
necessary to be done in connection therewith, as fully to all intents and purposes as he might or could do in person, 
hereby ratifying and confirming all that said attorney-in-fact and agent, or his substitutes or substitute, may lawfully 
do or cause to be done by virtue hereof. 

IN WITNESS WHEREOF, each of the undersigned has executed this Power of Attorney as of the date indicated 
opposite his/her name. 

Pursuant to the requirements of the Securities Act, this report has been signed by the following persons in the 
capacities and on the dates indicated. 

Signature 
/s/ RAMI ELGHANDOUR 
Rami Elghandour 

/s/ ANDREW H. GALLIGAN 
Andrew H. Galligan 

/s/ MICHAEL DEMANE 
Michael DeMane 

/s/ ALI BEHBAHANI 
Ali Behbahani, M.D. 

/s/ LISA EARNHARDT 
Lisa Earnhardt 

/s/ FRANK FISCHER 
Frank Fischer 

/s/ WILFRED E. JAEGER 
Wilfred E. Jaeger, M.D. 

/s/ SHAWN T MCCORMICK 
Shawn T McCormick 

/s/ BRAD H. VALE 
Brad H. Vale, Ph.D., D.V.M 

Title
Chief Executive Officer 
(Principal Executive Officer) 

Chief Financial Officer 
(Principal Financial and 
Accounting Officer) 

Date
February 23, 2017 

February 23, 2017 

Chairman of the Board 

February 23, 2017 

Director 

February 23, 2017 

Director 

February 23, 2017 

Director 

February 23, 2017 

Director 

February 23, 2017 

Director 

February 23, 2017 

Director 

February 23, 2017 

119 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit Index 

Incorporated
by 
Reference 
Form

Exhibit Description

Date

  Number 

 Filed Herewith

 Amended and Restated Certificate of Incorporation 
of Nevro Corp. 

8-K 

11/12/2014   

3.1 

Exhibit  
Number 

    3.1 

    3.2 

 Amended and Restated Bylaws of Nevro Corp. 

8-K 

11/12/2014   

3.1 

    4.1 

 Reference is made to exhibits 3.1 and 3.2. 

    4.2 

 Form of Common Stock Certificate. 

S-1/A 

10/27/2014   

    4.3 

    4.4 

 Indenture, dated as of June 13, 2016, by and 
between the Company and Wilmington Trust, 
National Association. 

 First Supplemental Indenture, dated as of June 13, 
2016, by and between the Company and 
Wilmington Trust, National Association. 

8-K 

6/13/2016 

4.2 

4.1 

8-K 

6/13/2016 

4.2 

    4.5 

 Form of 1.75% Convertible Senior Note Due 2021.

8-K 

6/13/2016 

4.3 

  10.1† 

 Amended and Restated License Agreement, dated 
October 2, 2006, by and among the Company and 
Mayo Foundation for Medical Education and 
Research, Venturi Group, LLC. 

S-1/A 

10/15/2014   

10.1 

  10.2(a)†   Stellar Manufacturing Agreement, dated as of 

S-1/A 

10/15/2014    10.2(a)      

July 1, 2009, by and between the Company and 
Stellar Technologies, Inc. 

  10.2(b)†   First Amendment to Stellar Manufacturing 

S-1/A 

10/15/2014    10.2(b)      

Agreement, dated as of July 1, 2014, by and 
between the Company and Stellar 
Technologies, Inc. 

  10.2(c)†   Second Amendment to Stellar Manufacturing 

10-K 

2/29/2016 

  10.2(c) 

Agreement, dated as of January 28, 2016, by and 
between the Company and Stellar Technologies, 
Inc.  

  10.3† 

 Supply Agreement, dated as of July 23, 2014 by and 
between the Company and Pro-Tech Design and 
Manufacturing, Inc. 

S-1/A 

10/15/2014   

10.3 

  10.4(a)†   Supply Agreement, dated April 1, 2012, by and 

S-1/A 

10/15/2014    10.4(a)      

between the Company and CCC del Uruguay S.A. 

  10.4(b)†   Amendment to Supply Agreement, dated as of 

S-1/A 

10/15/2014    10.4(b)      

March 20, 2013, by and between the Company and 
CCC del Uruguay S.A. 

  10.5(a)†   Product Supply and Development Agreement, dated 
as of April 15, 2009, by and between the Company 
and EaglePicher Medical Power LLC. 

S-1/A 

10/15/2014   

10.5 

  10.5(b)†   First Amendment to the Product Supply and 

10-K 

3/18/2015 

  10.5(b)     

Development Agreement, dated as of March 4, 
2015, by and between the Company and 

120 

 
 
 
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
    
 
   
 
 
 
   
   
 
  
   
    
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
 
    
 
   
 
 
 
 
   
 
    
 
   
 
 
 
 
   
 
    
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
 
   
 
 
 
 
   
 
   
 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
 
   
 
 
 
 
   
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
Exhibit  
Number 

Exhibit Description

EaglePicher Medical Power LLC. 

Incorporated
by 
Reference 
Form

Date

  Number 

 Filed Herewith

  10.5(c)†   Second Amendment to the Product Supply and 

10-K 

2/29/2016    10.5(c) 

Development Agreement, dated as of October 23, 
2015, by and between the Company and 
EaglePicher Medical Power LLC. 

  10.6(a) 

 Amended and Restated Registration Rights 
Agreement, dated February 8, 2013, by and among 
the Company and the investors listed therein. 

  10.6(b) 

  10.6(c) 

 Amendment to Amended and Restated Registration 
Rights Agreement, dated March 5, 2013, by and 
among the Company and the investors listed 
therein. 

 Second Amendment to Amended and Restated 
Registration Rights Agreement, dated October 24, 
2014, by and among the Company and the investors 
listed therein. 

  10.7(a) 

 Multi-Tenant Space Lease, dated as of March 15, 
2010, by and between Deerfield Campbell LLC and 
the Company. 

  10.7(b) 

 First Amendment to Lease, dated as of October 18, 
2012, by and between Deerfield Campbell LLC and 
the Company. 

  10.7(c) 

 Second Amendment to Lease, dated as of 
February 18, 2015, by and between Deerfield 
Campbell LLC and the Company. 

S-1 

10/03/2014    10.6(a)      

S-1 

10/03/2014    10.6(b)      

S-1/A 

11/04/14 

  10.6(c)      

S-1 

10/03/2014    10.7(a)      

S-1 

10/03/2014    10.7(b)      

10-K 

3/18/2015 

  10.7(c)     

  10.8(a)#   Nevro Corp. 2007 Stock Incentive Plan, as amended 

S-1 

10/03/2014    10.8(a)      

as of March 5, 2013. 

  10.8(b)#   Form of Incentive Stock Option Agreement (ISO) 
under the 2007 Stock Incentive Plan, as amended. 

S-1 

10/03/2014    10.8(b)      

  10.8(c)#   Form of Non-Incentive Stock Option Agreement 

S-1 

10/03/2014    10.8(c)      

(NSO) under the 2007 Stock Incentive Plan, as 
amended. 

  10.8(d)#   Form of Stock Purchase Right Grant Notice and 
Restricted Stock Purchase Agreement under the 
2007 Stock Incentive Plan, as amended. 

S-1 

10/03/2014    10.8(d)      

  10.9(a)#   Nevro Corp. 2014 Equity Incentive Award Plan. 

S-8 

11/12/2014    99.2(a)      

  10.9(b)#   Form of Stock Option Grant Notice and Stock 

S-1/A 

10/10/2014    10.9(b)      

Option Agreement under the 2014 Equity Incentive 
Award Plan. 

  10.9(c)#   Form of Restricted Stock Award Agreement and 
Restricted Stock Award Grant Notice under the 
2014 Equity Incentive Award Plan. 

S-1/A 

10/10/2014    10.9(c)      

  10.9(d)#   Form of Restricted Stock Unit Award Agreement 

S-1/A 

10/10/2014    10.9(d)      

121 

 
 
 
   
 
 
 
 
   
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
 
   
 
   
 
 
 
 
   
 
   
 
 
 
 
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
Exhibit  
Number 

Exhibit Description

and Restricted Stock Unit Award Grant Notice 
under the 2014 Equity Incentive Award Plan. 

Incorporated
by 
Reference 
Form

Date

  Number 

 Filed Herewith

  10.10# 

 Nevro Corp. 2014 Employee Stock Purchase Plan. 

S-8 

11/12/2014   

99.3 

  10.11# 

 Form of Indemnification Agreement for directors 
and officers. 

S-1/A 

10/10/2014    10.11 

  10.12(a)#  Offer Letter, dated as of March 8, 2011, by and 

S-1/A 

10/10/2014    10.12(a)     

between Michael DeMane and the Company. 

  10.12(b)#  Form of Employment Agreement by and between 
Michael DeMane and the Company. 

S-1/A 

10/10/2014    10.12(b)     

  10.12(c)#  Amendment to Employment Agreement, effective 

10-Q 

5/6/2016 

10.2 

as of June 1, 2016, by and between Michael 
DeMane and the Company. 

  10.13# 

 Offer Letter, dated as of October 9, 2012, by and 
between Rami Elghandour and the Company. 

S-1 

10/03/2014    10.13 

  10.13(b)#  Employment Agreement, effective as of June 1, 
2016, by and between Rami Elghandour and the 
Company. 

  10.14# 

 Offer Letter, dated as of May 12, 2010, by and 
between Andrew H. Galligan and the Company. 

10-Q 

5/6/2016 

10.3 

S-1 

10/03/2014    10.14 

  10.15# 

 Offer Letter, dated as of November 1, 2012, by and 
between Michael Enxing and the Company. 

S-1/A 

10/10/2014    10.15 

  10.16# 

 General Release and Separation and Transition 
Agreement, effective as of August 3, 2016, by and 
between Andre Walker and the Company. 

10-Q 

8/8/2016 

  10.13 

  10.18(a)   Amended and Restated Stockholders’ Agreement, 

S-1 

10/03/2014    10.15(a)     

dated February 8, 2013, by and among the 
Company and the stockholders listed therein. 

  10.18(b)   Amendment to Amended and Restated 

S-1 

10/03/2014    10.15(b)     

Stockholders’ Agreement, dated March 5, 2013, by 
and among the Company and the stockholders listed 
therein. 

  10.18(c)   Second Amendment to Amended and Restated 

S-1/A 

11/04/14 

  10.18(c)     

Stockholders’ Agreement, dated October 24, 2014, 
by and among the Company and the investors listed 
therein. 

  10.19# 

 Nevro Corp. Non-Employee Director Compensation 
Program. 

S-1/A 

10/10/2014    10.19 

  10.20(a)#  Form of Amended and Restated Change in Control 
Severance Agreement for certain executive officers.

10-Q 

5/9/2016 

10.4 

  10.20(b)#  Amended and Restated Change in Control 

10-Q 

8/8/2016 

  10.14 

Severance Agreement, dated as of May 5, 2016, by 
and between Andrew Galligan and the Company. 

122 

 
 
 
   
 
 
 
 
   
 
   
 
 
 
 
   
    
 
   
 
 
 
   
   
    
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
   
 
 
 
   
   
 
    
 
   
 
 
 
   
   
    
 
   
 
 
 
   
   
 
    
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
 
   
 
 
 
 
   
 
   
 
 
 
 
   
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
 
    
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
Exhibit  
Number 

Exhibit Description

Incorporated
by 
Reference 
Form

Date

  Number 

 Filed Herewith

  10.20(c)#  Amended and Restated Change in Control 

10-Q 

8/8/2016 

  10.15 

Severance Agreement, dated as of May 5, 2016, by 
and between Doug Alleavitch and the Company. 

  10.20(d)#  Amended and Restated Change in Control 

10-Q 

8/8/2016 

  10.16 

Severance Agreement, dated as of May 5, 2016, by 
and between Andre Walker and the Company. 

  10.20(e)#  Amended and Restated Change in Control 

10-Q 

11/7/2016 

10.2 

Severance Agreement, dated as of May 5, 2016, by 
and between Michael Enxing and the Company. 

  10.21(a)   Term Loan Agreement, dated October 24, 2014, by 

S-1/A 

10/27/2014    10.21 

and between the Company and Capital Royalty 
Partners II L.P. 

  10.21(b)   First Amendment to Term Loan Agreement, dated 
as of March 9, 2015, by and between the Company 
and Capital Royalty Partners II L.P. 

  10.21(c)   Second Amendment to Term Loan Agreement, 
dated as of June 29, 2015, by and between the 
Company and Capital Royalty Partners II L.P. 

  10.22(a)†  Supply Agreement, dated March 13, 2015, by and 
between the Company and Centro de Construccion 
de Cardioestimuladores del Uruguay S.A. 

  10.22(b)*  Supply Agreement, effective as of November 11, 

2016, by and between the Company and Centro de 
Construccion de Cardioestimuladores del Uruguay 
S.A. 

  10.23(a)   Lease Agreement, dated as of March 5, 2015, by 
and between the Company and Westport Office 
Park, LLC. 

  10.23(b)   First Amendment to Lease, effective as of 

December 9, 2016, by and between the Company 
and Westport Office Park, LLC 

  10.24# 

 Offer Letter, dated as of March 30, 2015, by and 
between the Company and Doug Alleavitch 

  10.25†*   Manufacturing and Supply Agreement, dated as of 
December 18, 2015, by and between the Company 
and Vention Medical Design and Development, Inc.

  10.26 

  10.27 

 Letter Agreement, dated June 7, 2016, between 
Morgan Stanley & Co. International plc and the 
Company, regarding the Base Warrants. 

 Letter Agreement, dated June 7, 2016, between 
Bank of America, N.A. and the Company, regarding 
the Base Warrants. 

10-K 

3/18/2015   10.21(b)     

10-Q 

8/6/2015 

10.2 

10-K/A 

5/29/2015 

  10.22 

10-K 

3/18/2015 

  10.23 

8-K 

4/9/2015 

10.1 

10-K 

2/29/2016    10.25 

8-K 

6/13/2016   

10.1 

8-K 

6/13/2016   

10.2 

X 

X 

123 

 
 
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
    
 
   
 
 
 
 
   
 
    
 
   
 
 
 
 
   
    
 
   
 
 
   
   
 
   
 
 
 
 
   
 
   
 
   
 
 
 
 
   
   
 
   
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
   
   
 
   
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
   
   
 
   
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
Exhibit  
Number 

  10.28 

  10.29 

  10.30 

  10.31 

  10.32 

  10.33 

  10.34 

  10.35 

  10.36 

  10.37 

Exhibit Description

 Letter Agreement, dated June 7, 2016, between 
Goldman, Sachs & Co. and the Company, regarding 
the Base Warrants. 

 Letter Agreement, dated June 7, 2016, between 
Morgan Stanley & Co. International plc and the 
Company, regarding the Base Call Option 
Transaction. 

 Letter Agreement, dated June 7, 2016, between 
Bank of America, N.A. and the Company, regarding 
the Base Call Option Transaction. 

 Letter Agreement, dated June 7, 2016, between 
Goldman, Sachs & Co. and the Company, regarding 
the Base Call Option Transaction. 

 Letter Agreement, dated June 8, 2016, between 
Morgan Stanley & Co. International plc and the 
Company, regarding the Additional Warrants. 

 Letter Agreement, dated June 8, 2016, between 
Bank of America, N.A. and the Company, regarding 
the Additional Warrants. 

 Letter Agreement, dated June 8, 2016, between 
Goldman, Sachs & Co. and the Company, regarding 
the Additional Warrants. 

 Letter Agreement, dated June 8, 2016, between 
Morgan Stanley & Co. International plc and the 
Company, regarding the Additional Call Option 
Transaction. 

 Letter Agreement, dated June 8, 2016, between 
Bank of America, N.A. and the Company, regarding 
the Additional Call Option Transaction. 

 Letter Agreement, dated June 8, 2016, between 
Goldman, Sachs & Co. and the Company, regarding 
the Additional Call Option Transaction. 

  21.1 

 List of Subsidiaries. 

  23.1 

  24.1 

  31.1 

  31.2 

 Consent of Independent Registered Public 
Accounting Firm. 

 Power of Attorney (included on signature page to 
this Annual Report on Form 10-K). 

 Certification of Chief Executive Officer pursuant to 
Section 302 of the Sarbanes-Oxley Act of 2002. 

 Certification of Chief Financial Officer pursuant to 
Section 302 of the Sarbanes-Oxley Act of 2002. 

  32.1** 

 Certification of Chief Executive Officer and Chief 
Financial Officer pursuant to 18 U.S.C. Section 

124 

Incorporated
by 
Reference 
Form

Date

  Number 

 Filed Herewith

8-K 

6/13/2016   

10.3 

8-K 

6/13/2016   

10.4 

8-K 

6/13/2016   

10.5 

8-K 

6/13/2016   

10.6 

8-K 

6/13/2016   

10.7 

8-K 

6/13/2016   

10.8 

8-K 

6/13/2016   

10.9 

8-K 

6/13/2016    10.10 

8-K 

6/13/2016    10.11 

8-K 

6/13/2016    10.12 

X 

X 

X 

X 

X 

X 

 
 
 
   
 
 
 
 
   
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
  
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
Exhibit  
Number 

Exhibit Description

1350, as adopted pursuant to Section 906 of the 
Sarbanes-Oxley Act of 2002. 

101.INS 

 XBRL Instance. 

101.SCH   XBRL Taxonomy Extension Schema. 

101.CAL   XBRL Taxonomy Extension Calculation Linkbase.

101.LAB   XBRL Taxonomy Extension Label Linkbase. 

101.PRE 

 XBRL Taxonomy Extension Presentation Linkbase.

101.DEF 

 XBRL Taxonomy Extension Definition Linkbase. 

Incorporated
by 
Reference 
Form

Date

  Number 

 Filed Herewith

X 

X 

X 

X 

X 

X 

† 

# 

* 

Confidential treatment has been granted for certain information contained in this exhibit. Such information 
has been omitted and filed separately with the Securities and Exchange Commission. 

Indicates management contract or compensatory plan. 

Portions of this exhibit (indicated by asterisks) have been omitted pursuant to a request for confidential 
treatment and this exhibit has been filed separately with the Securities and Exchange Commission. 

**  The certification attached as Exhibit 32.1 that accompanies this Form 10-K is not deemed filed with the 

Securities and Exchange Commission and is not to be incorporated by reference into any filing of Nevro Corp. 
under the Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended, whether 
made before or after the date of this Form 10-K, irrespective of any general incorporation language contained 
in such filing.

125 

 
 
 
   
 
 
 
 
   
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
   
 
 
 
   
 
 
 
  
   
 
 
[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

Exhibit 10.22(b) 

SUPPLY AGREEMENT 

CONFIDENTIAL 

by 

This SUPPLY AGREEMENT (the “Agreement”) is effective as of November 11, 2016 (the 
“Effective  Date”), 
between  CENTRO  DE  CONSTRUCCION  DE 
CARDIOESTIMULADORES  DEL  URUGUAY  S.A.,  a  Uruguay  corporation  having  its 
principal place of business at General Paz 1371, Montevideo, Uruguay, CP 11400 (“CCC”), and 
NEVRO  CORP.,  a  Delaware  corporation  having  its  principal  place  of  business  at  1800  Bridge 
Parkway, Redwood, City, California 94065 (“Nevro”). 

and 

1. 

DEFINITIONS 

Defined terms used in this Agreement shall have the meanings as defined in the text of 

the Agreement or as set forth in this Article 1: 

1.1 

“Affiliate” shall mean any other entity that directly or indirectly, through one or 
more intermediaries, controls, is controlled by or is under common control with the first entity, 
including, but not limited to, other entities which become Affiliates after the date of execution of 
this Agreement.  “Control” of an entity shall mean ownership of 50 percent or more of the total 
voting securities or other voting interests of the entity. 

1.2 

“Applicable  Law”  shall  mean  all  laws,  statutes,  ordinances,  codes,  rules,  and 
regulations  that  have  been  enacted  by  a  Governmental  Authority  and  are  in  force  as  of  the 
Effective Date or come into force during the Term, in each case to the extent applicable to the 
performance by the parties of their respective obligations under this Agreement. 

1.3 

“Approved  Manufacturer  List”  shall  mean  the  approved list  of  vendors  in  the 

Specifications for the supply of Components. 

1.4 

“Bill  of  Materials”  shall  mean  the  listing  or  reference  for  the  Components 
included  in  or  required  for  the  manufacture  of  each  Product  in  accordance  with  the 
Specifications,  which  Bill  of  Materials  is  set  forth  on  Exhibit  F  (as  such  exhibit  is  updated  in 
accordance with Section 4.1). 

1.5 

“Change  of  Control”  with  respect  to  a  Party  means  a  transaction  pursuant  to 
which  an  entity  acquires  all  or  substantially  all  of  the  assets  of  such  Party  related  to  this 
Agreement or acquires “control” of such Party, where “control” means: (i) ownership, directly or 
indirectly, of more than (a) fifty percent (50%) of the outstanding voting shares of such Party, or 
(b)  fifty  percent  (50%)  of  the  of  the  total  combined  voting  power  entitled  to  elect  or  appoint 
directors  or  persons  performing  similar  functions  for  such  Party,  or  (ii)  the  power  to  direct  or 
cause the direction of the management and policies of such Party by contract or otherwise. 

1.6 

“Components”  shall  mean  the  parts,  materials  and  supplies  included  in  or 

required for each Product as stipulated in the Bill of Materials. 

1.7 

“Confidential  Information”  shall  mean  any  and  all  confidential  or  proprietary 
business, technical, scientific and other know-how and information, including, but not limited to, 

1 

 
  
 
 
CONFIDENTIAL 

technology,  means,  methods,  processes,  practices,  formulas, 
trade  secrets,  knowledge, 
instructions,  skills,  techniques,  procedures,  specifications,  data,  results  and  other  material, 
manufacturing  procedures,  test  procedures,  and  any  tangible  embodiments  of  any  of  the 
foregoing,  and  any  scientific,  manufacturing,  marketing  and  business  plans,  any  financial  and 
personnel matters relating to a party or its present or future products, sales, suppliers, customers, 
employees, investors or business, that have been disclosed by or on behalf of such party to the 
other party in connection with this Agreement.  The terms of this Agreement shall be deemed the 
Confidential Information of both parties.  

1.8 

“Consigned  Components”  shall  mean  any  Components  designated  as 

“Consigned Components” on the Bill of Materials. 

1.9 

“Contract Year” means each calendar year during the Term, except that Contract 
Year 1 commences on the Effective Date and ends on December 31, 2016 and Contract Year 11 
commences  on  January  1,  2026  and  ends  on  the  date  that  is  ten  (10)  years  after  the  Effective 
Date. 

1.10 

“Defect” or “Defective” shall mean a defect caused by a breach of a warranty in 

Section 10.3.   

1.11  “Epidemic Failure” has the meaning specified in Section 8.5. 

1.12  “Equipment”  shall  mean  any  and  all  equipment  installed  at  the  Manufacturing 

Facility and used to manufacture the Products. 

1.13 

“FDA” means the United States Food and Drug Administration, or any successor 

entity thereto. 

1.14 

“Forecast” has the meaning specified in Section 2.1. 

1.15 

“Good  Manufacturing  Practice”  or  “GMP”  shall  mean  compliance  with  the 

most recent version of ISO13485 and the Quality System Regulations 21 CFR Part 820. 

1.16 

“Governmental  Authority”  shall  mean  any  supranational,  national,  regional, 
state or local government, court, governmental agency, authority, board, bureau, instrumentality, 
or regulatory body, including the FDA. 

1.17 

“CCC  IP”  shall  mean  the  Intellectual  Property  Rights  owned  or  otherwise 
controlled  by  CCC  necessary  for  the  manufacture  of  Products  for  Nevro  pursuant  to  this 
Agreement. 

1.18 

“Intellectual Property Right” means any patent or patent application, including 
with respect to patents rights granted upon any reissue, divisional, continuation or continuation-
in-part applications, utility models issued or pending, registered and unregistered design rights, 
copyright (including the copyright on software in any code), trademark, trade dress, trade secret, 
know-how,  or  any  other  intellectual  property  right  or  proprietary  right,  whether  registered  or 
jurisdiction.
unregistered,  and  whether  now  known  or  hereafter  recognized 

in  any 

2 

 
 
 
CONFIDENTIAL 

1.19 

“Inventory”  shall  mean  WIP  (i.e.,  Components  contained  in  partly  finished 
Products that are in various stages of the manufacturing process), finished Products (including, 
but  not  limited  to,  Safety  Stock),  Product-specific,  non-returnable  purchased  Components  and 
non-cancelable  purchase  orders  for  Components  outstanding  with  CCC’s  suppliers,  consistent 
with Section 2.3(c). 

1.20 

“Last Time Buy” shall mean Nevro’s option to order any quantities of Products 
totaling up to the quantities equal to [***] ([***]) times the volumes of such Products contained 
in  the  last  received  [***]  ([***])  month  Forecast,  subject  to  the  requirements  set  forth  in  this 
Agreement. 

1.21 

“Manufacturing  Facility”  shall  mean  the  CCC  facility  located  at  General  Paz 
1371, 11400 Montevideo, Uruguay, and any other facility approved by Nevro in accordance with 
Section 5.2(b) and that has been Qualified to manufacture the Products.   

1.22 

“NDS  Components”  shall  mean  all  Components  purchased  by  CCC  from  a 

Nevro Dictated Subcontractor. 

1.23 

“Nevro  Dictated  Subcontractor”  shall  mean  the  Subcontractors  identified  in 

Attachment 1 of the Quality Agreement as “Nevro Dictated Suppliers.” 

1.24 

“Nevro  IP”  shall  mean  the  Intellectual  Property  Rights  owned  or  otherwise 
controlled  by  Nevro,  solely  to  the  extent  necessary  for  the  manufacture  of  Products  for  Nevro 
pursuant to this Agreement.   

1.25 

“Nevro Property” shall mean (a) any tooling, equipment or software provided by 
Nevro, and (b) tooling or equipment developed or procured by CCC at Nevro’s expense but, with 
respect  to  tooling  or  equipment  developed  or  procured  by  CCC  at  Nevro’s  expense  after  the 
Effective Date, only if it has been invoiced separately from the purchase price of the Products, 
and (c) CCC’s Safety Stock upon Nevro’s payment of the applicable purchase price therefor.  

1.26 

“Nevro  System”  shall  mean  an  implantable  system  intended  to  be  completely 
introduced to a living body by surgical intervention to apply electrical stimulation for treatment 
of chronic pain.  

1.27 

“Products” shall mean the products that are listed in Exhibit A attached hereto, as 
well as any follow-on, modified, or improved versions of such products, or additional products, 
that the parties may mutually agree in writing to be subject to this Agreement.  

1.28 

“Purchase  Order”  shall  mean  a  written  purchase  order  issued  by  Nevro  for 

Products.   

1.29 

“Qualified” shall mean that the Manufacturing Facility and Equipment have been 
fully  qualified  by  CCC  to  supply  Nevro  with  such  Products  meeting  the  Specifications  and 
requirements  of  the  applicable  Governmental  Authorities. 
  To  remain  Qualified,  the 
Manufacturing  Facility  and  Equipment  must  (i)  be  maintained  as  specified  in  the  Quality 
Agreement and to at least the same conditions as when initially Qualified;  and (ii) continue to 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

3 

 
 
 
CONFIDENTIAL 

comply with all applicable requirements of any Governmental Authorities; in each case without 
any unapproved changes.  

1.30 

“Quality Agreement” shall mean the quality agreement executed by the parties 

and dated July 13, 2016, and any amendments thereto executed by the parties.  

1.31 

“Safety  Stock”  shall  mean  the  level  of  finished  Products  to  be  maintained  by 
CCC, in excess of the amount required to meet Nevro’s Purchase Orders, which level is specified 
in Section 2.2 below. 

1.32 

“Shipment Date” shall mean the shipment date from the Facility as specified in a 
Purchase  Order  that  is  consistent  with  the  Volume  Acceptance  Range  and  the  applicable  lead 
times for such Products as set forth on Exhibit A, or another date mutually agreed by the Parties 
in writing.  

1.33 

“Specifications”  shall  mean  Nevro’s  written  specifications  for  the  Products, 
including  the  current  revision  number,  Approved  Manufacturer  List,  Bills  of  Materials, 
manufacturing  procedures,  schematics,  testing  procedures,  drawings  and  documentation, 
including the specifications referenced on Exhibit B.  

1.34 

“Subcontractor”  shall  mean  any  component  supplier,  material  supplier,  service 
provider, consultant, contract laboratory, contractor, or other third party supplier who provides to 
CCC  any  product(s)  or  services  relating  to,  or  that  could  otherwise  reasonably  be  expected  to 
have any effect on, the Product, including any component or service related to the warehousing, 
storage or preparation of the Product. 

1.35 

“Tested NDS Component” has the meaning specified in Section 3.6(d).  

1.36 

“Validation  Documentation”  means  the  collection  of  all  documentation 
demonstrating that Product equivalence and all applicable regulatory requirements, and any other 
requirements  agreed  by  the  parties,  have  been  achieved  with  respect  to  a  proposed  new 
Manufacturing  Facility, 
including  master  validation  plans,  qualification  documentation 
(including  operational  qualification  documentation),  performance  qualification  documentation 
(including protocols and reports), line validation/product performance qualification protocols and 
reports,  and  process  failure  modes  and  effects  analysis  documentation.  The  Validation 
Documentation is intended to be delivered as a package and considered for approval as such. 

1.37  “Volume Acceptance Range” has the meaning specified in Section 2.5. 

1.38 

“Warranty  Period”  shall  mean,  for  each  Product,  the  period  of  eighteen  (18) 

months immediately following the date the Product is received by Nevro.   

2. 

PRODUCT PURCHASE  

2.1 

Forecasts.    Following  execution  of  this  Agreement,  and  on  a  monthly  basis 
thereafter,  Nevro  will  provide  CCC  with  a  [***]  ([***])  month  rolling  forecast  of  Nevro’s 
expected monthly order volume for each of the Products for the forthcoming [***] ([***]) month 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

4 

 
 
 
CONFIDENTIAL 

period  (each,  a  “Forecast”).  Nevro  agrees  to  update  the  Forecast  monthly.    The  first  [***] 
([***]) months of the Forecast will be considered binding (provided for clarity that no forecast 
with respect to the IPG 2000 shall be binding unless and until the IPG 2000 has been approved 
by Nevro in accordance with Exhibit A), and the last [***] ([***]) months of the Forecast will be 
considered non-binding. If Nevro’s Purchase Orders for the [***] ([***]) month period covered 
by  a  binding  Forecast  are  for  a  quantity  less  than  the  volume  of  Products  specified  in  the 
Forecast for such [***] ([***]) month period (the “Shortfall”), Nevro will revise such Purchase 
Orders or submit additional Purchase Orders.     

2.2 

In-Stock Product Minimum.  CCC agrees to carry at its own cost Safety Stock 
levels of each Product to accommodate Product purchases by Nevro, as calculated based on the 
applicable  Forecast  for  the  period  and  in  an  amount  equal  to  [***]  ([***])  [***]  worth  of 
expected Product orders in the applicable Forecast.  CCC agrees to fulfill Purchase Orders first 
from such Safety Stock inventory, and to manufacture sufficient units of the Products to maintain 
the forecasted levels in the Safety Stock inventory.  The Safety Stock inventory will be available 
to  ship  to  Nevro  within  [***]  ([***])  [***]  of  Nevro  placing  a  Purchase  Order.  If  the  Safety 
Stock  inventory  drops  below  the  [***]  ([***])  [***]  level  at  any  time,  CCC  will  promptly 
replenish it within [***] ([***]) [***].  Nevro is responsible in accordance with Section 11.4 for 
such  Inventory  that  was  reasonably  and  customarily  necessary  to  sustain  Safety  Stock  levels.  
The parties may agree from time to time to alter the number of Product units for each Product 
that need to be maintained in the Safety Stock inventory.   

2.3 

Component Supply.   

(a) 

CCC shall maintain and manage adequate Component inventory in order 
to  meet  Nevro’s  Purchase  Orders.  CCC  shall  immediately  notify  Nevro  in  the  event  of  any 
potential material delays or shortages that may impact CCC’s delivery of Products in accordance 
with the applicable Forecast or Purchase Orders.      

(b) 

CCC may order a reasonable volume of Components above the quantities 
required  to  satisfy  Purchase  Orders  in  order  to  meet  Component  minimum  order  quantities 
imposed by Component suppliers. 

(c) 

Subject to the remainder of this Section 2.3(c), Nevro shall be responsible 
for the cost/price of finished Products and Safety Stock (as such prices are set forth on Exhibit 
A) and the cost of other types of Inventory purchased or manufactured by CCC under the terms 
of  this  Agreement  which  becomes  obsolete  due  to  reduction  in  demand  (i.e.,  which  were 
reasonably  ordered  based  on  a  Forecast  including  but  not  limited  to  the  Product  requirements 
contained in the binding portion of the Forecast and the Components ordered that were ordered 
consistent  with  the  non-binding  portion  of  the  Forecast  due  to  long  Component  lead  times)  or 
due  to  Change  Orders  (if  such  finished  Products,  Safety  Stock  and  other  Inventory  were 
identified by either party as becoming obsolete in such mutually agreed Change Order), provided 
that CCC has made a reasonable effort to return such Inventory or cancel the applicable orders 
from Subcontractors (except that this obligation on CCC to return or cancel will not apply in the 
case of finished Products, Safety Stock, and WIP). In the event of such obsolescence, CCC shall 
notify Nevro in writing of the applicable Inventory, which notice shall explain the reason such 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

5 

 
 
 
CONFIDENTIAL 

Inventory  became  obsolete  and  shall  include  invoices  and  other  documentation  that  show  the 
cost to CCC of such Inventory. 

(d) 

If Nevro engages in a process pursuant to which Nevro accepts bids from 
third parties to supply Components, Nevro shall (i) notify CCC in writing of Nevro’s intent to 
engage a third party with respect to such Components within a reasonable period of time prior to 
the  scheduled  commencement  of  such  process,  (ii)  provide  CCC  with  a  general  written 
description  of  Nevro’s  requirements  with  respect  to  such  Components,  and  (iii)  provide  CCC 
with an opportunity to submit a bid to provide such Components to Nevro. Nevro shall discuss 
any such submitted bid with CCC in good faith. If Nevro does not accept CCC’s bid in any such 
process, Nevro shall inform CCC in reasonable detail of the reasons for such non-acceptance.  

2.4 

Purchase  Orders.    During  the  Term  of  this  Agreement,  Nevro  shall  issue 
Purchase  Order(s)  for  the  order  volume  of  each  of  the  Products  specified  in  the  binding  [***] 
([***]) month portion of each Forecast. Each Purchase Order shall include at least the following: 
(a) Nevro’s Purchase Order number; (b) identification of the Products ordered by Nevro; (c) the 
Shipment  Date;  and  (d) any  shipping  instructions,  including  preferred  carrier  and  shipping 
destination.  Nevro and CCC agree that a Purchase Order sent to CCC by confirmed facsimile or 
electronic transmission shall constitute a writing for all legal purposes.  In addition, the parties 
may communicate regarding Purchase Orders via mutually agreeable electronic means, such as 
confirmed electronic mail.  

2.5 

Purchase  Order  Acceptance.    CCC  will  accept  all  Purchase  Orders  that  have 
Shipment Dates that conform to Section 2.4 and that order volumes of Products that are within 
[***] percent ([***]%) and [***] percent ([***]%) of the Forecast for the applicable period (the 
“Volume  Acceptance  Range”).    CCC  will,  within  five  (5)  business  days  after  receipt  of  a 
Purchase  Order,  notify  Nevro  of  acceptance  of  such  Purchase  Order  or  will  indicate  the 
Shipment Dates that do not comply with Section 2.4 or the order volumes that are not within the 
Volume Acceptance Range.  Nothing contained in any Nevro Purchase Order or CCC Purchase 
Order  acknowledgement  shall  modify  the  terms  of  purchase  or  add  any  additional  or  different 
terms or conditions except as otherwise specifically agreed in writing by the parties and any pre-
printed or similar terms or conditions that may be incorporated in such Nevro Purchase Order or 
CCC Purchase Order acknowledgement are hereby rejected.   

2.6 

Revision of Purchase Orders.  In the event that Nevro cancels a Purchase Order 
inside  the  standard  lead  time  for  a  Product  as  set  forth  on  Exhibit  A,  then  Nevro  will  be 
responsible  for  all  finished  Product,  WIP,  raw  material,  components  and  any  non-cancelable 
purchase  orders  outstanding  with  suppliers  directly  related  to  the  cancelled  Purchase  Order.  In 
the event that Nevro cancels a Purchase Order outside of the standard lead time for a Product, 
Nevro  and  CCC  will  negotiate  the  resulting  costs.    Nevro  may  change  an  accepted  Purchase 
Order  only  if  agreed  upon  in  writing  by  CCC,  but  CCC  shall  use  its  commercially  reasonable 
efforts to accommodate increases, decreases or reschedules of the quantities in a Purchase Order 
requested  by  Nevro.  Any  additional  costs  of  such  change  approved  by  Nevro  prior  to  the 
implementation of such change will be borne by Nevro.   

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

6 

 
 
 
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2.7  Minimum Purchase Thresholds.  During the Term, and subject to the terms and 
conditions of this Agreement, Nevro will satisfy the minimum purchase thresholds as defined in 
Exhibit A (such obligations, the “Minimum Purchase Thresholds”).  

2.8 

Reduction  of  Minimum  Purchase  Thresholds.    If  during  the  Term  of  this 
Agreement with respect to any Product, for any reason: (a) CCC fails to supply non-Defective 
Products in accordance with this Agreement with respect to at least [***] percent ([***]%) of the 
amount of the Product scheduled on a Purchase Order accepted in accordance with Section 2.5 (a 
“Purchase Order Failure”); or (b) [***] percent ([***]%) or more of a shipment of the Product 
delivered by CCC does not meet the applicable Specifications (a “Defect Failure”); or (c) such 
Product  is  subject  to  an  Epidemic  Failure;  then  (i)  Nevro  may  require  CCC  to  increase  Safety 
Stock  inventory  specified  in  Section  2.2  up  to  [***]  ([***])  [***]  worth  of  expected  Product 
orders,  and  (ii)  the  Minimum  Purchase  Thresholds  for  the  year  or  years  in  which  such  events 
occur will be [***] in connection with a Purchase Order Failure or the [***] affected by a Defect 
Failure  or  Epidemic  Failure.  In  addition,  in  the  case  of  an  extended  interruption  of  supply  of 
sixty  (60)  consecutive  days  or  more,  CCC  and  Nevro  agree  to  negotiate  in  good  faith  further 
reductions in the Minimum Purchase Thresholds until such time as CCC is in a position to satisfy 
future Purchase Orders.  

3. 

SUPPLY 

3.1 

Delivery.    Delivery  of  all  Products  shall  be  made  EXW  (Incoterms  2010) 
Manufacturing  Facility.    Title  to  and  risk  of  loss  for  the  Products  shall  pass  to  Nevro  at  the 
delivery point.  Nevro shall be responsible for paying freight, handling, shipping and insurance 
charges that it approves in writing in advance for shipments to destinations requested by Nevro.  
CCC  shall  deliver  the  Products  to  Nevro  on  or  before  the  applicable  Shipment  Date  and  in 
accordance with the shipping instructions in the applicable Purchase Order, including the ship-to 
address,  carrier  and  means  of  transportation  or  routing.    Nevro  may  return  any  unauthorized  
over-shipment or any portions thereof, at CCC’s expense and without charge to Nevro.  If Nevro 
fails to provide shipping instructions, CCC will make the selection of carrier on a commercially 
reasonable basis. 

3.2 

Notification  of  Delay.  Without  limiting  Nevro’s  rights  and  remedies  under  this 
Agreement, if circumstances arise that prevent CCC from making the Products available on the 
Shipment  Date,  CCC  shall  (i)  immediately  notify  Nevro  of  the  nature  of  the  problem,  the 
methods  taken  to  overcome  the  problem  and  the  estimated  time  of  delay,  and  (ii)  expedite 
shipment of such Products when the problem is overcome.   

3.3 

Product  Quality.    CCC  shall  test  and  inspect  all  Products  before  shipment  for 
compliance  with  the  Specifications,  all  Applicable  Laws,  and  the  Quality  Agreement  and  shall 
provide to Nevro written certification that each Product shipped was manufactured in compliance 
with  the  foregoing.    In  addition,  CCC  shall  comply  with  its  obligations  under  the  Quality 
Agreement and Good Manufacturing Practice with respect to all Manufacturing Facilities and the 
manufacture of the Products.  Upon receipt of each shipment of Products, Nevro, or a third party 
designated  by  Nevro,  may  test  and  inspect  such  Products  for  compliance  with  the  foregoing.

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

7 

 
 
 
3.4 

Rejection.  Nevro must conduct any incoming inspection tests not later than 45 
days from the date of its receipt of the Products. Products not rejected by Nevro by written notice 
to CCC within such period will be deemed accepted, with the exception of Products with defects 
that  are  not  readily  observable  by  Nevro.  Any  Defective  Products  may  be  returned  to  CCC  in 
accordance with Section 10.3(b).  For clarity, nothing in this Section 3.4 modifies or otherwise 
affects Nevro’s rights and remedies under Section 10 with respect to any Products. 

CONFIDENTIAL 

3.5 

Consigned Components. 

(a) 

In the event that Nevro supplies certain Consigned Components to CCC, 
such  Consigned  Components  shall  be  delivered  to  CCC  in  sufficient  time  and  in  sufficient 
quantities  based  on  Purchase  Orders  and  in  accordance  with  this  Agreement,  including  normal 
yield levels, to allow CCC to meet scheduled Shipment Dates for the applicable Products.  All 
Consigned Components shall be in good condition and in good working order.  Nevro assumes 
complete liability for the quality of all Consigned Components and CCC shall not be responsible 
for any Defects or deficiencies therein.  CCC shall, upon receipt of the Consigned Components, 
perform all necessary inspections of the Consigned Components, in accordance with its standard 
procedures and shall notify Nevro in writing, not later than twenty (20)  Days  from  the  date  of 
receipt of the Consigned Components, of any Defects found or of any discrepancy in quantities. 
CCC reserves the right, after receipt of the Consigned Components, to timely inform Nevro of 
additional Defects which may be discovered or revealed by further inspection by or through the 
manufacturing process that could not be discovered at incoming inspection by CCC. 

(b) 

CCC  will  provide  Nevro  with  a  written  statement  of  the  Consigned 

Components used by CCC at the end of each calendar month. 

3.6 

Subcontractors.  

(a) 

Use of Subcontractors.  CCC will not use any Affiliate or Subcontractor 
for any supply of Components or services related to the Product without the prior written consent 
of  Nevro.    If  Nevro  consents  to  the  use  of  an  Affiliate  or  Subcontractor,  Nevro  may  specify 
change  control  procedures  applicable  to  the  provision  of  services  by  such  Affiliate  or 
Subcontractor in addition to the terms of Section 5. 

(b) 

  Except 

Verification  of  Subcontractors. 

for  Nevro  Dictated 
Subcontractors,  CCC  shall  establish  and  maintain  written  requirements,  including  quality 
requirements,  for  evaluating,  selecting,  and  assessing  any  Subcontractors  and  shall  ensure  that 
each  Subcontractor  is  qualified  and  able  to  provide  the  product(s)  or  service(s)  (including 
Components)  required  to  perform  its  required  tasks  or  services  in  accordance  with  the 
Specifications,  all  Applicable  Laws,  and  this  Agreement.    CCC  shall  establish  and  maintain 
appropriate quality requirements to ensure the performance of Subcontractors (other than Nevro 
Dictated  Subcontractors)  in  accordance  with  the  terms  and  conditions  of  this  Agreement, 
Applicable  Laws,  CCC’s  standard  operating  procedures,  and,  if  any,  Nevro’s  written 
instructions.    CCC  shall  use  commercially  reasonable  efforts  to  ensure  Nevro  has  the  right  to 
audit  CCC’s  Subcontractors  to  assure  compliance  with  this  Agreement  and  any  regulatory 
requirements, and CCC shall include such right for Nevro to conduct such audits (including the 
right to access facilities and records) in any applicable contract CCC has with a Subcontractor. 

8 

 
 
 
CONFIDENTIAL 

(c) 

Liability  for  Subcontractors.    CCC  shall  be  responsible  for  keeping  all 
Subcontractors adequately informed and ensuring that the correct design, production, or process 
controls  are  applied  to  Subcontractor  as  applicable  to  ensure  that  the  Product,  including  any 
Component  therein,  conforms  to  the  Specifications.    With  the  exception  of  Nevro  Dictated 
Subcontractors, CCC is responsible for the acts and omissions of any Subcontractor as if those 
acts and omissions had been carried out by CCC. 

(d) 

Nevro  Dictated  Subcontractors.    In  the  event  that  a  Nevro  Dictated 
Subcontractor  supplies  NDS  Components  to  CCC,  CCC  shall  (i)  conduct  inspection  and 
acceptance testing on such NDS Components in accordance with section 7.16 and Attachment 2 
of the Quality Agreement (“NDS Component Testing”), (ii) use in the manufacture of Products 
only NDS Components that have passed the properly conducted NDS Component Testing (each, 
a  “Tested  NDS  Component”),  (iii)  notify  Nevro  of  any  NDS  Components  that  fail  the  NDS 
Component Testing within thirty (30) days after such failure, (iv) use commercially reasonable 
efforts  to  cause  such  Nevro  Dictated  Subcontractor  to  deliver  such  NDS  Components  in 
sufficient time and in sufficient quantities based on Purchase Orders and in accordance with this 
Agreement to allow CCC to meet scheduled Shipment Dates for the applicable Products, and (v) 
notify Nevro in  writing within five (5) business  days  of  any  shipment  delay,  NDS  Component 
quality  issue  or  other  business  or  performance  concern  with  respect  to  any  Nevro  Dictated 
Subcontractor (each, an “NDS Component Subcontractor Issue”), which writing shall describe 
in detail the NDS Component Subcontractor Issue and any actions CCC has taken with respect to 
such  issue.  Subject  to  and  without  limiting  CCC’s  obligations  set  forth  immediately  above,  (i) 
Nevro  will  be  responsible  for  qualifying,  monitoring,  and  managing  all  Nevro  Dictated 
Subcontractors  in  accordance  with  Nevro’s  internal  procedures,  (ii)  except  as  set  forth  herein, 
CCC  shall  not  be  responsible  for  the  quality  of  NDS  Components  that  have  passed  properly 
conducted NDS Component Testing in accordance with the Quality Agreement and  CCC shall 
not  be  responsible  for  costs  related  to  or  arising  from  defects  or  deficiencies  in  any  NDS 
Components that have passed properly conducted NDS Component Testing in accordance with 
the Quality Agreement, including, without limitation, costs and expenses related to the repair or 
replacement  (including  shipping  and  handling  expenses)  of  any  Defective  Products  that  are 
Defective  due  to  such  defective  or  deficient  NDS  Components  that  have  passed  properly 
conducted NDS Component Testing in accordance with the Quality Agreement, provided that in 
each case that any such defect or deficiency could not have reasonably been discovered during 
NDS Component Testing and was not caused by CCC in its handling of such NDS Component 
or  during  the  manufacturing  process,  (iii)  without  limiting  CCC’s  obligation  to  properly  test 
NDS  Components,  CCC  reserves  the  right,  after  receipt  of  the  NDS  Components,  to  timely 
inform Nevro of additional defects which may be discovered or revealed by further inspection by 
or  through  the  manufacturing  process  that  could  not  be  reasonably  discovered  during  NDS 
Component  Testing,  (iv)  upon  receipt  of  a  notice  of  an  NDS  Component  Subcontractor  Issue, 
Nevro  will  work  with  CCC  and  use  reasonable  efforts  to  cause  such  Nevro  Dictated 
Subcontractor  to  deliver  non-defective  NDS  Components  in  sufficient  time  and  in  sufficient 
quantities  based  on  Purchase  Orders  and  in  accordance  with  this  Agreement,  including  normal 
yield levels, to allow CCC to meet scheduled Shipment Dates for the applicable Products and (v) 
failure or delay of CCC to perform fully any of its obligations under this Agreement caused by 
defects  or  deficiencies  in  any  NDS  Component  that  has  passed  properly  conducted  NDS 
Component  Testing  (which  defects  or  deficiencies  could  not  have  reasonably  been  discovered 
during  NDS  Component  Testing  and  were  not  caused  by  CCC  in  its  handling  of  such  NDS 

9 

 
 
 
Component  or  during  the  manufacturing  process)  or  the  non-performance  or  delay  of  a  Nevro 
Dictated Subcontractor in delivering non-defective NDS Components will be deemed not to be a 
breach of this Agreement if such NDS Components or the Nevro Dictated Subcontractor’s non-
performance  or  delay  were  the  primary  cause  of  CCC’s  failure  or  delay  to  fully  perform  such 
obligations. 

CONFIDENTIAL 

4. 

PRICE; PAYMENT 

4.1 

Product Purchase Price.  Nevro shall pay to CCC the prices for the Products set 
forth in Exhibit A attached hereto. Notwithstanding the preceding sentence, (a) subject to clause 
(b)  of  this  Section  4.1,  if  there  is  a  net  increase  or  decrease  of  $[***]  or  more  in  the  [***]  a 
Product ([***]), which increase or decrease shall be [***]), then a corresponding change equal to 
[***] percent ([***]%) of the documented amount of such increase or decrease will be made to 
the  price  of  the  applicable  Product.  The  parties  shall  meet  at  least  twice  per  Contract  Year  to 
calculate  the  amount  of  any  such  increase  or  decrease  and,  if  any  increase  or  decrease  in  the 
Product  price  is  made  as  a  result  of  any  such  meeting,  the  parties  shall  update  the  [***]  after 
such meeting to reflect the change in the [***] such increase or decrease. CCC shall provide to 
Nevro documentation [***] such increase or decrease.  All Purchase Orders for Products issued 
by  Nevro  after  the  parties'  agreement  regarding  the  amount  of  such  increase  or  decrease  shall 
reflect the adjusted Product price. For clarity, Nevro shall [***] with respect to [***].   

4.2 

Invoices;  Payments.    CCC  shall  invoice  Nevro  for  the  Products  on  or  after  the 
date on which CCC ships the Product to Nevro.  All such invoices shall be submitted by CCC to 
Nevro  via  email.  Nevro  shall  pay  all  undisputed  amounts  within  thirty  (30)  days  following 
Nevro’s receipt of CCC’s invoice.  All payments under this Agreement shall be in U.S. dollars. 
All amounts referenced in or to be paid under this Agreement, exclude taxes, customs, shipping, 
insurance and duties.  CCC agrees to notify Nevro of any past due amounts and reserves the right 
to charge interest on any such undisputed amounts which remain past due for ten (10) days after 
such notification at the rate of 1.5% per month or the highest rate allowed by law, whichever is 
lower. In addition to all other available rights and remedies on default, CCC may refuse orders, 
require advance payment in full, ship C.O.D. or halt shipments if all undisputed prior invoices 
are not paid in full within 10 days after CCC notifies Nevro in writing of the applicable past due 
amounts under such invoices.   

4.3 

Taxes.    Nevro  agrees  to  pay  any  applicable  sales,  use,  excise  or  similar  taxes, 
including value added taxes and customs duties, itemized on the applicable invoice and arising 
from  purchases  made  by  Nevro  under  this  Agreement,  but  not  any  taxes  based  on  CCC’s  net 
income. 

4.4 

Cost Reduction Initiatives. CCC shall collaborate with Nevro to make proposals 
that, if implemented, would deliver a reduction in the cost of the Product, including by reducing 
Component and manufacturing costs and improving Product yields. CCC shall provide to Nevro 
a  plan  detailing  cost  reduction  efforts  that  CCC  proposes  to  undertake  to  achieve  the  cost 
reductions, which must be approved by Nevro, which approval may be provided or withheld in 
Nevro’s  sole  discretion.    The  parties  shall  meet  at  least  twice  per  Contract  Year  to  review  the 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

10 

 
 
 
 
 
CONFIDENTIAL 

cost  reduction  efforts.    Nevro  and  CCC  will  mutually  agree  upon  the  business  case  analysis, 
including  expenses,  cost  savings  and  implementation  schedule.    Cost  reduction  efforts  or 
proposals  shall  not  compromise  quality  or  reliability,  and  CCC  shall  comply  with  Product 
Specifications  and  Good  Manufacturing  Practices.    If  CCC  and  Nevro  share  the  expenses 
associated with the implementation, cost savings shall be split [***] percent ([***]%) to Nevro 
and [***] percent ([***]%) to CCC.  If either party pays the full cost of such implementation (as 
such payment responsibility is specified in the approval of such implementation), then that party 
will receive [***] percent ([***]%) of the demonstrated cost reduction. For avoidance of doubt, 
for  design  changes  in  a  Product  that  are  initiated  by  Nevro  and  for  which  the  implementation 
costs  are  paid  by  Nevro,  Nevro  will  receive  [***]%  of  the  demonstrated  cost  reduction  upon 
implementation.    CCC  shall  give  Nevro  notice  of  the  implementation  of  the  foregoing  cost 
reductions as soon as practicable, but in any event within thirty (30) days of the accomplished 
reduction.  After  any  such  implementation,  all  invoices  shall  reflect  the  applicable  reduced 
pricing and the parties shall work to update Exhibit A accordingly.    

5. 

PROCESS CHANGE NOTIFICATION 

5.1 

Specification  Change  Process.    If,  during  the  Term  of  this  Agreement,  Nevro 
wishes  to  engage  CCC  with  respect  to  a  change  to  any  Specifications,  including  critical  raw 
material specifications and sourcing, for any Product then being manufactured by CCC, it shall 
give  CCC  written  notice  of  such  request  (a  “Change  Order”).    CCC  shall  respond  to  such 
Change  Order,  including  any  pricing  change  driven  by  such  Change  Order  (provided  that  any 
such pricing change shall be consistent with [***]), and the parties shall thereupon negotiate in 
good  faith  for  a  written  change  to  such  Specifications,  incorporating  the  modifications  to  the 
Specifications  and  any  associated  regulatory  approvals  and  facility  qualifications  required  as  a 
result.    CCC  may  not  reject  reasonable  Change  Orders  requested  by  Nevro  and  CCC  shall 
promptly implement any Change Orders.  Except as specified in this Section 5.1, CCC may not 
change  the  manufacturing  process  of  the  Products  except  in  accordance  with  the  Quality 
Agreement. Any Inventory that will be rendered unusable as a result of a Change Order shall be 
identified in such Change Order and CCC shall provide documentation reasonably supporting the 
unusability of such Inventory. [***]   

5.2 

Notification of Changes.   

(a) 

Equipment Change.  CCC shall notify Nevro of all proposed changes to 
any Equipment that may affect the Products or any certification, approval, or qualification by any 
Governmental  Authority.    Any  such  notice  shall  be  provided  in  accordance  with  the  Quality 
Agreement.   

(b)  Manufacturing Facility Change.  Two options exist for the relocation of 

the manufacturing facility as described in clauses (i) and (ii) below.  

If CCC desires to relocate the manufacturing of the Product from 
the  Manufacturing  Facility  to  the  location  specified  on  Exhibit  E,  CCC  shall  provide  written 
notice  to  Nevro  and  shall  provide  an  updated  schedule  for  such  relocation  and  such  other 

(i) 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

11 

 
 
 
 
CONFIDENTIAL 

information  reasonably  required  by  Nevro  with  respect  to  such  proposed  new  location.  
Following  the  notice,  CCC  shall  deliver  to  Nevro  qualification  parts  manufactured  at  such 
proposed  new  location  and  the  Validation  Documentation  with  respect  to  such  proposed  new 
location for Nevro’s review and approval (which approval shall not be unreasonably withheld).  
CCC  shall  not  ship  any  Product  manufactured  at  the  new  location  until  CCC’s  receipt  of  a 
written notice from Nevro that it is ready to receive Product manufactured at the new facility (the 
“Facility  Approval  Notice”).  CCC  will  use  reasonable  commercial  efforts  to  qualify  and 
otherwise  achieve  all  regulatory  approvals  necessary  for  the  relocation  and  the  manufacture  of 
Products at the new location as soon as possible, excluding any such approvals with respect to 
the Product that Nevro itself is legally required to obtain (“Nevro Approvals”).  Nevro will use 
reasonable commercial efforts to achieve the Nevro Approvals as soon as possible after Nevro’s 
approval of the Validation Documentation.  Nevro shall provide reasonable cooperation to CCC 
in  connection  with  the  qualification  of  such  new  facility,  and  CCC  shall  provide  reasonable 
cooperation  to  Nevro  in  connection  with  obtaining  the  Nevro  Approvals.      If  Nevro  does  not 
issue  the  Facility  Approval  Notice  within  [***]  ([***])  days  after  all  regulatory  approvals 
(including Nevro Approvals) necessary to manufacture the Product at the new location have been 
obtained and CCC has reasonably demonstrated that it can manufacture Products in accordance 
with  this  Agreement  at  such  new  location,  then  all  prices  for  the  Products  will  automatically 
[***] ([***]%) unless and until Nevro issues the Facility Approval Notice.  Nevro understands 
and agrees that the relocation of the Manufacturing Facility located at General Paz 1371, 11400 
Montevideo, Uruguay is accounted for in the pricing in Exhibit A, and therefore, [***] will be 
made  as  result  of  such  relocation.        Unless  agreed  upon  by  the  parties,  each  party  will  be 
responsible for their direct costs associated with the move, including all costs related to internal 
Product  and  process  validation,  equipment  purchase  and  implementation  and  integration  costs. 
Notwithstanding  the  foregoing,  CCC  will  be  responsible  for  (i)  the  third  party  expenses  [***] 
with the [***] for such relocation (ii) the cost of [***] required in connection with [***] required 
in connection with such relocation.   

(ii) 

Based on business requirements and agreed upon by both parties in 
writing, the manufacturing of a Product could be relocated to a CCC site located in the United 
States.  All requirements identified in  Section 5.2(b)(i) above must be successfully  completed 
before such Product can be shipped from the new location. The NRE cost associated with this 
facility  relocation  will  be  negotiated  in  good  faith  between  the  parties  prior  to  the  time  the 
facility relocation is to be executed.   The unit price for the Products manufactured at such new 
facility will be in accordance with Exhibit A, unless otherwise agreed to by the parties.   

(c) 

Change  Approval.    CCC  shall  comply  with  the  Quality  Agreement  for 

the implementation of any changes to any process, system, or activity relating to the Product. .   

6. 

PERSONNEL; FACILITIES; EQUIPMENT; NEVRO PROPERTY 

6.1 

Personnel.  CCC shall ensure that all of its personnel engaged in the storage, 

handling, packaging, distribution, or other processing of the Products shall have the education, 
training and experience reasonably sufficient to perform their assigned functions in accordance 
with Applicable Laws.

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

12 

 
 
 
 
6.2 

Facilities.  CCC shall ensure that the Manufacturing Facility shall be orderly and 
maintains (i) reasonably adequate lighting, ventilation and water supply for the activities relating 
to the Product, (ii) space for performing the activities required under this Agreement, and (iii) the 
ability to reasonably separate discrete operations or processes relating to the Product in order to 
prevent mixing, product errors or other contamination of Product.   

CONFIDENTIAL 

6.3 

Equipment.   

(a) 

CCC shall bear all costs of maintenance and repair, including validation, 
periodic  calibration,  as  required,  and  preventive  maintenance,  of  the  Equipment,  whether 
required as a result of routine and ordinary wear or otherwise.    

(b) 

CCC shall secure and maintain in good order, at its sole cost and expense, 
all  current  governmental  registrations,  permits  and  licenses  that  are  required  by  Governmental 
Authorities in order for CCC to use the Equipment and to manufacture the Products under this 
Agreement.  CCC shall make copies of such registrations available for viewing by Nevro and its 
designees for inspection, upon reasonable request from Nevro. CCC agrees to promptly inform 
Nevro of any injury that occurs on manufacturing and testing equipment that is owned by Nevro 
but in a CCC Manufacturing Facility.    

6.4 

Nevro Property.  Any Nevro Property shall reside and/or remain the property of 
Nevro  and  shall  (a)  be  clearly  marked  or  tagged  as  the  property  of  Nevro,  (b)  be  and  remain 
personal  property,  and  not  become  a  fixture  to  real  property,  (c)  be  subject  to  inspection  by 
Nevro at any time, (d) be used solely for the purpose of supplying the Products to Nevro, (e) be 
kept free by CCC from any and all liens and encumbrances, (f) not be modified in any manner by 
CCC without the prior written approval of Nevro, and (g) be maintained by CCC in accordance 
with Nevro’s maintenance procedures and guidelines, including, if applicable, but not limited to, 
periodic calibration procedures.  Nevro will pay all maintenance costs of Nevro Property.  Nevro 
shall retain all rights, title and interest in Nevro Property and CCC agrees to treat and maintain 
the Nevro Property with the same degree of care as CCC uses with respect to its own property, 
but  no  less  care  than  reasonable  care.    All  processes  and  specifications  related  to  the  Nevro 
Property  shall  constitute  Nevro’s  Confidential  Information.  CCC  shall  bear  all  risk  of  loss  or 
damage to the Nevro Property, normal wear and tear excepted, until it is returned or delivered to 
Nevro.  Upon  Nevro’s  request,  CCC  shall  deliver  all  of  the  Nevro  Property  to  Nevro  in  good 
condition,  normal  wear  and  tear  excepted,  without  cost  to  Nevro  (except  freight  costs);  Nevro 
shall  determine  the  manner  and  procedure  for  returning  the  Nevro  Property,  and  shall  pay  the 
corresponding  freight  costs.    CCC  agrees  to  execute  all  documents,  or  instruments  evidencing 
Nevro’s ownership of the Nevro Property as Nevro may require from time to time.   

7. 

SUSPENSION OF MINIMUM PURCHASE THRESHOLDS  

In the event that an injunction, exclusion order, or cease and desist order is issued by any 
relevant court or tribunal, which thereby prevents the sale, manufacturing, or importation of  a 
Product    due  to  such  Product  infringing  the  intellectual  property  rights  of    a  third  party,  the 
parties  agree  to  suspend  the  Minimum  Purchase  Thresholds  for  such  Product  until  the 

13 

 
 
 
CONFIDENTIAL 

injunction,  exclusion  order,  or  cease  and  desist  order  is  lifted  or  terminated  (a  “Minimum 
Purchase Suspension”).   The Minimum Purchase Suspension shall terminate and Nevro shall 
immediately  commence  its  obligations  to  satisfy  the  Minimum  Purchase  Thresholds  upon  the 
termination  or  lifting  of  the  applicable    injunction,  exclusion  order,  or  cease  and  desist  order.  
Nevro  shall  use  its  best  efforts  to  prevent  any  such  injunction,  exclusion  order,  or  cease  and 
desist order from being issued. desist order from being issued. If an injunction, exclusion order, 
or cease and desist order is issued despite Nevro’s best efforts, Nevro shall use its best efforts to 
obtain a judgment vacating, terminating or lifting any such injunction, exclusion order, or cease 
and  desist  order  as  soon  as  possible  after  the  issuance  thereof,  to  the  extent  it  is  legally 
permissible to do so.   

8. 

PROGRAM  MANAGEMENT;  PRODUCT  SUPPORT;  COMPLAINTS  AND  ADVERSE  EVENTS; 
EPIDEMIC FAILURE  

8.1 

Program  Management.  Each  party  shall  provide  a  list  of  program  team 
members.  The  list  shall  include  name,  title,  phone  number,  and  email  address.  The  Program 
Team List is attached as Exhibit D. 

8.2 

Technical Support.  CCC agrees to provide Nevro reasonable technical support 
and assistance upon request regarding questions about the Specifications and the manufacturing 
processes  for  the  Products.    Any  charges  for  such  assistance  (beyond  normal  manufacturing 
assistance  consistent  with  standard  contract  manufacturing)  will  be  agreed  upon  by  the  parties 
and paid for by Nevro. 

8.3  Other Support.  Each party shall, in response to any complaint, or in the defense 
by the other party of any litigation, hearing, regulatory proceeding or investigation relating to the 
Product,  make  available  to  the  other  party  during  normal  business  hours  and  upon  reasonable 
prior  written  notice,  such  party’s  employees  and  records  reasonably  necessary  to  permit  the 
effective  response  to,  defense  of,  or  investigation  of  such  matters,  subject  to  appropriate 
confidentiality protections. Any charges for such assistance will be agreed upon by the parties. 

8.4 

Epidemic Failure.   

(a) 

For  the  purposes  of  this  Agreement,  epidemic  failure  will  be  deemed  to 
have  occurred  if  there  is  an  occurrence  of  an  in-field  failure  rate  of  [***]  percent  ([***]%)  or 
more of the total units of Product delivered by CCC to Nevro in any [***] month period and the 
root cause of such failure is [***] (“Epidemic Failure”).  In the event of an Epidemic Failure, 
CCC and Nevro will cooperate to implement the following procedure: 

(i) 

The  discovering  party  shall  promptly  notify  the  other  party  upon 
discovery of the failure; provided, however, that, in the event of a failure that creates a risk of 
injury  or  death,  the  discovering  party  will  immediately  notify  the  other  party  and  will  also 
provide the other party with written notice within [***] ([***]) business hours of any notification 
made  by  the  discovering  party  to  any  Governmental  Authority  responsible  for  regulation  of 
product safety.   

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

14 

 
 
 
 
CONFIDENTIAL 

(ii)  Within  [***]  ([***])  business  day  after  such  notification,  CCC 
shall  provide  to  Nevro  a  preliminary  plan  for  diagnosing  the  problem,  which  plan  CCC  will 
revise on Nevro’s request; 

plan a solution or corrective action; 

(iii)  CCC and Nevro shall jointly diagnose the problem (root cause) and 

appropriate corrective action plan; and 

(iv)  CCC  shall  prepare  and  consult  with  Nevro  regarding  an 

CCC  and  Nevro  shall  mutually  agree  on  a  corrective  action  plan, 
customer notification, replacement scheduling and remediation, which may include a recall, field 
action, and return inventory replacement, and repair. 

(v) 

Notwithstanding the foregoing, Nevro may undertake any and all action necessary independently 
of CCC to correct the Epidemic Failure and shall communicate such action to CCC; provided, 
that CCC is unable or unwilling to promptly correct the Epidemic Failure.  

(b) 

Any  Defective  Products  subject  to  Epidemic  Failure  (including  those 
Defective Products outside of the Warranty Period) may be returned to CCC in accordance with 
Section 10.3b. 

9. 

REGULATORY ACTION 

9.1 

Regulatory Inspection.  In the event that CCC receives notice of any inspection 
by a Governmental Authority of the Manufacturing Facility that involves or otherwise relates to 
the Product, CCC shall notify Nevro within twenty-four (24) hours of its receipt of such notice.  
CCC  will  cooperate,  including  access  to  the  Manufacturing  Facility,  Records  and  CCC 
personnel,  as  reasonably  necessary  to  support  any  such  inspection  and  provide  communication 
and access to Nevro in accordance with the Quality Agreement.   

9.2 

Recalls. 

(a) 

Incidents  and  Product  Recalls.    CCC  shall  notify  Nevro  within  [***] 
([***]) business day of any information which may affect the safety or the continued marketing 
of the Product, including any information relating to: (i) any Product, including any production 
lot, being made subject to any correction and/or removal, including a recall, market withdrawal 
or  stock  recovery  (collectively,  a  “Recall”),  regardless  of  whether  such  Recall  is  initiated  by 
CCC,  Nevro  and/or any third party, including  a  Governmental Authority; (ii) any incident that 
would cause the Product or its labeling to be mistaken for, or applied to, another article; or (iii) 
any contamination or any significant chemical, physical, or other change or deterioration in such 
Product that would cause it to fail to meet the Specifications; or (iv) any other matter that would 
require a report to the FDA concerning the Product. 

Cooperation.    In  the  event  either  party  believes  it  may  be  necessary  to 
conduct  a  Recall,  CCC  and  Nevro  shall  consult  with  each  other  as  to  how  best  to  proceed,  it 

(b) 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

15 

 
 
 
 
CONFIDENTIAL 

being understood and agreed that the final decision as to any Recall of any end product in which 
the  Product  is  included  shall  be  at  Nevro’s  sole  discretion,  following  consultation  with  CCC.  
Nevro will be responsible for, and oversee, notification of any such Recall for such end product 
sold  by  Nevro  to  its  customers  and  will  provide  CCC  with  a  final  report  to  confirm  that  the 
Recall  was  performed  in  compliance  with  Applicable  Law.    In  any  event,  with  respect  to  any 
such  Recall,  Nevro  shall  make  all  contacts  with  the  FDA  and  shall  be  responsible  for 
coordinating all necessary activities in connection with the Recall.  CCC will fully cooperate, at 
CCC’s sole expense, in providing all requested information to Nevro, including any request by 
Nevro  that  CCC  (i)  investigate  such  Recall,  (ii)  provide  Nevro  with  an  initial  response  or 
preliminary  report  relating  to  the  circumstances  leading  to  the  Recall,  and  (iii)  secure  any 
recalled Product to prevent further distribution.  

9.3 

Confidentiality.  All information disclosed or exchanged pursuant to this Section 
9 shall be treated as Confidential Information of the disclosing party and shall not be disclosed to 
any  third  party  without  the  original  party’s  prior  written  consent,  unless  such  disclosure  is 
permitted under Section 13.3(d). 

10. 

REPRESENTATIONS, WARRANTIES AND COVENANTS 

10.1  Representations,  Warranties  and  Covenants  of  CCC.    CCC  represents  and 

warrants to Nevro that: 

(a) 

as  of  the  Effective  Date,  CCC  is  duly  organized,  validly  existing,  and  in 
good standing under the laws of New York and has full corporate power and authority to enter 
into this Agreement;  

(b) 

as  of  the  Effective  Date,  CCC  is  in  good  standing  with  all  applicable 

Governmental Authorities;  

(c) 

as of the Effective Date, CCC has taken all corporate actions necessary to 
authorize  the  execution  and  delivery  of  this  Agreement  and  the  performance  of  CCC’s 
obligations under this Agreement;  

(d) 

the  performance  of  CCC’s  obligations  under  this  Agreement  do  not 
materially  conflict  with,  or  constitute  a  material  default  under  CCC’s  charter  documents,  any 
contractual obligation of CCC or any court order; 

(e) 

neither  CCC  nor  any  of 

its  employees,  agents,  consultants  and 
Subcontractors  is  debarred,  suspended,  proposed  for  debarment,  or  otherwise  determined  to  be 
ineligible  to  participate  in  federal  health  care  programs  (as  that  term  is  defined  in  42  U.S.C. 
1320a-7b(f)  or  under  any  analogous  foreign  counterpart),  or  convicted  of  a  criminal  offense 
related to the provision of health care items or services; 

(f) 

CCC  shall  not,  during  the  term  of  this  Agreement,  undertake  any 

obligation that conflicts with CCC’s obligations under this Agreement; 

16 

 
 
 
 
 
(g) 

CCC  has  obtained  all  material  licenses,  permits,  authorizations,  and 
permissions  necessary  or  requisite  under  Applicable  Law  for  meeting  and  performing  its 
obligations  under  this  Agreement,  and  all  such  material  licenses,  permits,  authorizations,  and 
permissions are in full force and effect and shall be kept in full force and effect during the term 
of this Agreement; 

CONFIDENTIAL 

(h) 

the  appropriate 
Governmental  Authorities  and  in  compliance  with  all  applicable  Governmental  Authority 
standards and Applicable Laws;  

the  Manufacturing  Facility 

registered  with 

is 

(i) 

CCC  shall  manufacture  all  Products  at  and  supply  all  Products  from  the 
Manufacturing Facility, and CCC shall not, without Nevro’s prior written consent, manufacture 
Products at or supply Products from any facility other than the Manufacturing Facility;  

(j) 

CCC shall transfer to Nevro good and clear title to the Products, free and 

clear of all liens, claims and encumbrances;  

(k) 

CCC  has  the  right  to  grant  the  rights  granted  by  CCC  hereunder  and 
CCC’s  manufacturing  process  and  its  performance  of  services  under  this  Agreement  will  not 
infringe any Intellectual Property Right of any third party;  

(l) 

CCC  shall  not  sell  or  otherwise  transfer  the  Products  to  any  third  party, 

other than as consented to by Nevro in writing; and  

(m) 

 CCC has the right and power to enter into this Agreement.   

10.2  Representations,  Warranties  and  Covenants  of  Nevro.    Nevro represents and 

warrants to CCC that  

(a) 

as of the Effective Date, Nevro is duly organized, validly existing and in 
good  standing  under  the  laws  of  Delaware  and  has  full  corporate  power  and  authority  to  enter 
into this Agreement;  

(b) 

as  of  the  Effective  Date,  Nevro  is  in  good  standing  with  all  applicable 

Governmental Authorities; 

(c) 

as of the Effective Date, Nevro has taken all corporate actions necessary to 
authorize  the  execution  and  delivery  of  this  Agreement  and  the  performance  of  Nevro’s 
obligations under this Agreement;  

(d) 

the  performance  of  Nevro’s  obligations  under  this  Agreement  do  not 
materially  conflict  with,  or  constitute  a  material  default  under  Nevro’s  charter  documents,  any 
contractual obligation of CCC or any court order; 

(e) 

its  employees,  agents,  consultants  or 
Subcontractors  is  debarred,  suspended,  proposed  for  debarment,  or  otherwise  determined  to  be 
ineligible  to  participate  in  federal  health  care  programs  (as  that  term  is  defined  in  42  U.S.C. 

neither  Nevro  nor  any  of 

17 

 
 
 
 
CONFIDENTIAL 

1320a-7b(f)  or  under  any  analogous  foreign  counterpart),  or  convicted  of  a  criminal  offense 
related to the provision of health care items or services; 

(f) 

Nevro  shall  not,  during  the  term  of  this  Agreement,  undertake  any 

obligation that conflicts with Nevro’s obligations under this Agreement; 

(g) 

Nevro  has  obtained  all  material  licenses,  permits,  authorizations,  and 
permissions  necessary  or  requisite  under  Applicable  Law  for  meeting  and  performing  its 
obligations  under  this  Agreement,  and  all  such  material    licenses,  permits,  authorizations,  and 
permissions are in full force and effect and shall be kept in full force and effect during the term 
of this Agreement; and 

(h) 

Nevro has the right and power to enter into this Agreement.   

10.3  Performance Warranty and RMA Process.   

(a) 

CCC warrants  that during the  Warranty Period each Product will be free 
from defects in material and workmanship, will conform to the relevant Specifications, and will 
have  been  manufactured  in  accordance  with  Good  Manufacturing  Practices  and  otherwise  in 
accordance  with  this  Agreement.    In  the  event  that  any  Product  does  not  conform  to  such 
warranty, CCC will repair or replace such Product (or refund the price paid therefor) as provided 
for in Section 10.2(b).      

(b) 

Any Defective Products may be returned to CCC  and CCC will, at its sole 
expense  (including  shipping  and  handling  expenses),  either  (i)  repair  the  applicable  Defective 
Products  within  a  reasonable  time  (which  shall  be  no  greater  than  the  lead  time  set  forth  on 
Exhibit  A  for  the  applicable  Product);  (ii)  replace  the  applicable  Defective  Products  within  a 
reasonable  time  (which  shall  be  no  greater  than  the  lead  time  set  forth  on  Exhibit  A  for  the 
applicable  Product);  and/or  (iii)  and  if  neither  of  (i)  or  (ii)  is  feasible  within  such  time,  upon 
Nevro’s  request  and  without  limiting  Nevro’s  rights  and  remedies  under  this  Agreement,  CCC 
will refund the amount of the payments paid for the Product; provided that (i) Nevro obtains a 
return  authorization  from  CCC  prior  to  returning  the  Products  (and  CCC  shall  provide  Nevro 
with  an  RMA  number  promptly  upon  request),  and  the  failure  analysis,  or  summary  thereof, 
conducted by Nevro shall accompany the Product or shall otherwise be promptly be delivered to 
CCC.  If  the  Product  returned  to  CCC  is  not  covered  by  the  warranty  (because  the  return  was 
outside the Warranty Period or was found not to be Defective Product) CCC may charge Nevro 
for any services performed on the Product. 

(c) 

Notwithstanding  any  other  provision  of  this  Agreement,  CCC  shall  have 
no obligation to Nevro under the limited warranty set forth in Section 10.3(a) or under Section 
14.1 to the extent that (a) the Product is not used in accordance with the Specifications; (b) the 
Product  has  had  modifications,  alterations,  repairs  or  work  performed  on  it  by  any  party  other 
than CCC or CCC’s authorized agents; (c) the failure is due to incorrect use or handling of the 
Products by Nevro or third parties after Nevro accepts such Product; (d) the failure is due to a 
defect  in  a  Tested  NDS  Component  (which  defect  could  not  have  reasonably  been  discovered 
during NDS Component Testing and which failure or defect was not caused by CCC or its agents 

18 

 
 
 
 
in its handling of such Tested NDS Component or otherwise during the manufacturing process), 
or (e) Nevro has not complied with Section 10.3(b) (collectively, the “Section 10.3(c) Causes”).    

CONFIDENTIAL 

10.4  Disclaimer of Warranties.   

(a) 

EXCEPT  FOR  THE  WARRANTIES  MADE  IN  SECTIONS  10.1  AND 
10.3,  CCC  MAKES  NO  OTHER  WARRANTIES,  EXPRESSED  OR  IMPLIED,  WITH 
RESPECT TO THE COMPONENTS, PRODUCTS OR ANY SERVICES PROVIDED UNDER 
THIS  AGREEMENT,  AND  DISCLAIMS  ALL  OTHER  WARRANTIES  INCLUDING  THE 
WARRANTIES  OF  MERCHANTABILITY,  NON-INFRINGEMENT  AND  FITNESS  FOR  A 
PARTICULAR  PURPOSE  OR  ARISING  FROM  A  COURSE  OF  DEALING,  USAGE  OR 
TRADE PRACTICE. 

(b) 

EXCEPT FOR THE WARRANTIES MADE IN SECTION 10.2, NEVRO 
MAKES NO OTHER WARRANTIES WITH RESPECT  TO THE NEVRO INTELLECTUAL 
PROPERTY,  CONSIGNED  COMPONENTS,  NEVRO  PROPERTY,  THE  LICENSES 
GRANTED  HEREUNDER  OR  OTHER  MATERIALS  OR  DOCUMENTATION  PROVIDED 
BY NEVRO HEREUNDER AND DISCLAIMS ALL OTHER WARRANTIES, EXPRESS OR 
NON-INFRINGEMENT, 
IMPLIED, 
MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR ARISING FROM A 
COURSE OF DEALING, USAGE OR TRADE PRACTICE. 

THE  WARRANTIES 

INCLUDING 

OF 

11. 

TERM AND TERMINATION 

11.1  Term.    Unless  earlier  terminated  pursuant  to  the  terms  and  conditions  of  this 
Agreement, this Agreement shall commence on the Effective Date and shall remain in full force 
and  effect  for  ten  (10)  years.    Thereafter,  this  Agreement  will  be  automatically  extended  for 
additional  two  (2)  year  periods  unless  one  party  notifies  the  other  in  writing  one  (1)  year  in 
advance that it does not intend to renew the Agreement for an additional term (all such renewal 
periods and the initial term collectively being the “Term”). 

11.2  Termination by Nevro.  Nevro may terminate this Agreement by providing three 
(3) years written notice to CCC in the event a Change of Control of CCC occurs, provided that 
such notice period shall be one (1) year in the event CCC is acquired by a competitor to Nevro 
such as but not limited to St. Jude Medical, Boston Scientific or Medtronic or an Affiliate of any 
such  entities.    Such  notice  shall  be  given  by  Nevro  not  less  than  [***]  ([***])  days  after  the 
effective date of any Change of Control or Nevro’s rights under this Section 11.2 shall expire.  

11.3  Termination for Certain Events.  Either party may terminate the Agreement by 

providing written notice to the other party, upon the occurrence of any of the following events: 

(a) 

if  the  other  party  ceases  to  do  business,  or  otherwise  terminates  its 
business operations, excluding any situation where all or substantially all of such other party’s 
assets, stock or business to which this Agreement relates are acquired by a third party (whether 
by sale, acquisition, merger, operation of law or otherwise); 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

19 

 
 
 
 
 
CONFIDENTIAL 

(b) 

if  the  other  party  breaches  any  material  provision  of  this  Agreement  and 
fails to cure such breach within [***] ([***]) days of written notice describing the breach, except 
that  an  undisputed  breach  of  the  payment  provision  of  this  Agreement  must  be  cured  within 
[***] ([***]) day of written notice describing the breach; or 

(c) 

if  the  other  becomes  insolvent,  makes  an  assignment  for  the  benefit  of 
creditors,  files  a  petition  in  bankruptcy,  permits  a  petition  in  bankruptcy  to  be  filed  against  it, 
presents a petition or has a petition presented by a creditor for its winding up, or enters into any 
liquidation  or  call  any  meeting  of  its  creditors,  or  admits  in  writing  that  it  is  unable  to  pay  its 
debts as they mature, or if a receiver or examiner is appointed for a substantial part of its assets.  

11.4  Consequences of Termination.   

(a) 

Upon  any  termination  or  expiration  of  this  Agreement,  unless  otherwise 
agreed to by the parties, CCC shall continue to fulfill, subject to the terms of this Agreement, all 
Purchase Orders placed by Nevro and accepted by CCC in accordance with this Agreement prior 
to  the  effective  date  of  termination  or  expiration.  Notwithstanding  the  foregoing,  if  this 
Agreement  is  terminated  by  CCC  in  accordance  with  Section  11.3,  then  CCC  shall  not  be 
required to fulfill its obligations on any Purchase Orders.  Furthermore, CCC shall promptly turn 
over to Nevro all Products (and Nevro shall pay for such Products at the then-current price) and 
the  Specifications,  whether  or  not  completed,  and  both  parties  shall  promptly  turn  over  to  the 
respective party the Confidential Information of such party.  

11.5  Accrued Rights.  Termination or expiration of this Agreement for any reason will 
not  affect  the  rights  and  obligations  of  the  parties  accrued  prior  to  the  effective  date  of  the 
termination or expiration of this Agreement. 

11.6  Survival.  The following Articles and Sections of this Agreement shall survive its 
termination or expiration:  Articles 1, 4 (solely to the extent payment obligations remain after the 
effective date of such termination or expiration), 9, 10, 11, 12, 13, 14, 15, 16 and 17 and Sections 
6.4 and 8.3 and 8.4. 

11.7  Last  Time  Buy.  In  the  event  of  any  termination  (excluding  CCC’s  termination 
pursuant  to  Section  11.3  or  termination  pursuant  to  Section  11.2)  or  non-renewal  of  this 
Agreement, Nevro shall have the option to make a Last Time Buy.   If Nevro provides the notice 
of termination, then Nevro must provide the Last Time Buy order at the same time it provides the 
notice of termination.  If CCC provides the notice of termination under Section 11.1, then Nevro 
must provide the Last Time Buy order at least [***] ([***]) months prior to the effective date of 
termination and must take delivery of such Last Time Buy within [***] ([***]) months of such 
order.  Any Last Time Buy under Section 11.1 or Section 11.2 will be subject to a price increase 
equal to [***] (i.e., [***]), provided that such incremental costs shall not exceed [***]% of the 
price  of  the  applicable  Products.  CCC  shall  provide  invoices  and  other  reasonably  detailed 
costs.  
documentation 

demonstrate 

amount 

such 

the 

of 

to 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

20 

 
 
 
 
 
11.8  Termination  of  Predecessor  Agreement.  The  parties  agree  that  as  of  the 
Effective Date the Supply Agreement between Centro De Construccion de Cardioestimuladores 
del Uruguary S.A. and Nevro Corp. dated March 13, 2015 is terminated.  CCC warrants that it 
has the power and authority to terminate such agreement.   

CONFIDENTIAL 

12. 

INTELLECTUAL PROPERTY 

12.1  Pre-Existing Property. The term “Pre-Existing Property” means all rights of a 
party  to  designs,  inventions  (whether  patentable  or  not),  copyrights,  trademarks,  trade  secrets, 
processes, software, devices and other Intellectual Property Rights and confidential information 
owned or held by a party immediately prior to the Effective Date. The parties acknowledge and 
agree that all Pre-Existing Property is the property of the party or its licensors that owned such 
property  immediately  before  the  Effective  Date  and  that,  except  as  expressly  set  out  herein, 
nothing in this Agreement shall convey or otherwise grant any rights in or to any Pre-Existing 
Property from one party to the other party. 

12.2  Resulting  Property.  The  term  “Resulting  Property”  means  all  designs,  data, 
information,  inventions,  improvements,  discoveries,  methods,  processes  (in  each  case  whether 
patentable  or  not),  software,  and  devices  and  any  Intellectual  Property  Rights  in  any  of  the 
foregoing (including copyrights, trademarks, trade secrets, and patent rights) developed by either 
party as a result of this Agreement. 

12.3  Grant  of  License.    To  the  extent  that  any  Resulting  Property  or  any  materials, 
goods  or  services  to  be  delivered  or  provided  by  CCC  to  Nevro  under  this  Agreement 
(“Deliverables”)  incorporate  in  any  manner  any  of  the  Pre-Existing  Property  of  CCC  or  any 
improvements to or derivatives of the Pre-Existing Property of CCC (the “Incorporated CCC 
Property”),  CCC  hereby  grants  to  Nevro  and  its  Affiliates  and  successors  and  assigns  a 
perpetual,  irrevocable,  fully  paid,  worldwide,  sublicensable,  non-exclusive  license  under  the 
Incorporated CCC Property and all Intellectual Property Rights therein to make, use, sell, offer 
for sale, and import the Incorporated CCC Property and all Intellectual Property Rights therein, 
in connection with such Resulting Property or Deliverables and any improvements, derivatives 
or  successor  works  of  or  to  such  Resulting  Property  and  Deliverables  as  Nevro  considers 
appropriate,  including  to  use,  manufacture,  sell,  offer  for  sale,  import,  display,  copy,  perform, 
modify, alter and support the Incorporated CCC Property and any products or services in which 
such  property  is  incorporated.  The  license  granted  to  Nevro  includes  the  rights  to  future 
improvements  to  or  derivatives  of  the  Incorporated  CCC  Property  to  the  extent  such 
improvements or derivatives are utilized in connection with a Deliverable, but it does not require 
CCC  to  take  any  actions  or  perform  any  activities  to  incorporate  such  property  into  any 
deliverable  in  connection  with  the  Resulting  Property  or  Deliverables,  or  any  improvements, 
derivatives or successor works thereof or thereto. Nothing in this Agreement will be deemed to 
grant Nevro the right to market, sub-license or otherwise use the Pre-Existing Property of CCC 
other than in connection with one or more Deliverables or the Resulting Property and products or 
services in which they are incorporated, or improvements, derivatives or successor works of the 
foregoing.    

12.4  Ownership  of  Resulting  Property.  The  parties  acknowledge  and  agree  that  all 
Resulting Property and all Intellectual Property Rights therein, excluding the Incorporated CCC 

21 

 
 
 
 
CONFIDENTIAL 

Property and any changes or improvements to the Incorporated CCC Property made by CCC and 
all  Intellectual  Property  Rights  therein,  shall  be  solely  owned  by  Nevro.  CCC  shall  promptly 
disclose  any  such  Resulting  Property  to  Nevro.  CCC  hereby  assigns,  and  shall  cause  all  of  its 
employees,  agents,  Affiliates,  Subcontractors  and  other  authorized  representatives  to  assign,  to 
Nevro any and all interests it or they may have in any such Resulting Property and all Intellectual 
Property  Rights  therein.  CCC  agrees  to  cooperate  with  Nevro,  at  Nevro’s  expense,  for  the 
purpose  of  filing  and  prosecuting  patent  and  other  Intellectual  Property  Right  applications  in 
connection  with  the  Resulting  Property,  including  the  execution  of  any  and  all  legal  papers 
which are necessary or desirable to affect the intent of this Section 12.4. 

13. 

CONFIDENTIAL INFORMATION 

13.1  Confidentiality  Obligations.    Each  party  agrees  that,  during  the  Term  of  this 
Agreement  and  thereafter,  such  party  shall  maintain  all  Confidential  Information  of  the  other 
party in strict confidence, and shall not use such Confidential Information for any purpose other 
than  to  perform  its  obligations  or  exercise  its  rights  under  this  Agreement.      A  receiving  party 
may disclose Confidential Information to its directors, officers, employees, authorized agents and 
professional  advisers  to  the  extent  such  persons  have  a  need  to  know  such  information  for  the 
purpose  of  performing  such  party’s  duties  and  obligations  or  exercising  such  party’s  rights 
hereunder, provided that such party advises each such individual of the terms of this Section 13 
and  ensures  that  each  such  individual  receives  and  hold  such  information  as  if  that  individual 
were a party to this Agreement. 

13.2  Exceptions  to  Confidentiality.    The  foregoing  obligations  in  Section  13.1  will 
not apply to any portion of Confidential Information to the extent that it can be established by the 
receiving party with competent proof that such portion: 

(a) 

was  already  known  to  the  receiving  party  as  evidenced  by  its  written 

records, other than under an obligation of confidentiality, at the time of disclosure; 

(b) 

was  generally  available  to  the  public  or  was  otherwise  part  of  the  public 

domain at the time of its disclosure to the receiving party; 

(c) 

became generally available to the public or otherwise becomes part of the 
public  domain  after  its  disclosure  and  other  than  through  any  act  or  omission  of  the  receiving 
party in breach of this Agreement; or 

is  independently  developed  by  the  receiving  party  without  use  of  the 
Confidential Information received from the disclosing party, as evidenced by its written records;  

(d) 

(e) 

was subsequently lawfully disclosed to the receiving party by a third party 
other  than  in  contravention  of  a  confidentiality  obligation  of  such  third  party  to  the  disclosing 
party. 

13.3  Authorized Disclosures.  Each party may disclose the other party’s Confidential 
Information to the extent such disclosure is reasonably necessary to  (i) perform its obligations or 
exercise its rights under this Agreement and such disclosure is made to a third party who has a 

22 

 
 
 
 
CONFIDENTIAL 

need  to  know  the  Confidential  Information  and  who  agrees  to  be  bound  by  confidentiality 
restrictions at least as restrictive as those contained in this Agreement, and (ii) to comply with 
Applicable Law, a court order, or rules of a securities exchange.  If a party is required to make 
any such disclosure of the other party’s Confidential Information under this Section 13.3, it will 
give reasonable advance notice to the other party of such disclosure requirement, will reasonably 
cooperate with the other party in its efforts to secure confidential treatment of such Confidential 
Information  prior  to  its  disclosure,  and  will  use  all  reasonable  efforts  to  secure  confidential 
treatment  of  such  Confidential  Information  prior  to  its  disclosure  (whether  through  protective 
orders or confidentiality agreements or otherwise). 

13.4  Ownership  and  Return  of  Confidential  Information.    All  Confidential 
Information provided hereunder shall remain the property of the disclosing party.  The receiving 
party  shall,  within  ten  days  of  a  written  request  to  do  so,  return  to  the  disclosing  party  all 
Confidential Information that has been provided in tangible form and shall, unless prohibited by 
law,  destroy  or  otherwise 
Information. 
Notwithstanding the foregoing, each party will be allowed to keep one copy of the Confidential 
Information in order to ensure continued compliance with the terms of this Agreement. 

render  unintelligible  all  other  Confidential 

13.5  Equitable  Relief.   The parties acknowledge that monetary  damages  may  not  be 
sufficient remedy for a breach of obligation of confidentiality in this Agreement and agree that 
each Party shall be entitled to seek appropriate equitable remedies, including injunctive relief, to 
prevent the unauthorized use or disclosure of any Confidential Information. 

13.6  Public  Announcements.    Except  to  the  extent  required  by  Applicable  Law, 
neither  party  shall  make  any  public  announcements  concerning  this  Agreement  or  the  terms 
hereof without the prior written consent of the other party.   

14. 

INDEMNIFICATION.   

14.1  CCC shall indemnify and hold Nevro and its Affiliates and its and their directors, 
officers,  agents,  employees,  and  consultants  (the  “Nevro  Indemnitees”)  harmless  from  and 
against  any  liabilities,  damages,  losses,  costs,  and  expenses  (including  reasonable  attorneys’ 
fees) ) which the Nevro Indemnitees may incur or suffer as a result of claims by third parties to 
the proportionate extent they result from or arise out of (i) any (A) personal injury or death or (B) 
other claim caused by a breach by CCC of the limited warranty set forth in Section 10.3(a), (ii) 
any  violation  of  law  by  CCC,  (iii)  the  gross  negligence  or  intentionally  wrongful  conduct  of 
CCC,  and  (iv)  a  breach  of  the  representations,  warranties  or  covenants  in  Section  3.3,  Section 
10.1,  and  Section  13.    Nevro  shall  promptly,  and  in  any  event,  within    thirty  (30)    days,  after 
Nevro first learns of such claim, notify CCC of such claim tender the sole defense of such claim 
to  CCC  (provided  CCC  diligently  pursues  such  defense),  and  cooperate  with  CCC  at  CCC’s 
expense in connection with such defense. 

14.2  Nevro will indemnify, defend and hold harmless CCC and its Affiliates and each 
of  their  officers,  directors,  shareholders,  employees,  agents,  successors  and  assigns  (the  “CCC 
Indemnitees”)  against  any  and  all  losses,  obligations,  liabilities,  damages,  actions,  settlements, 
judgments and reasonable  costs  and  expenses which the CCC Indemnitees may incur  or  suffer 
(including, but not limited to, reasonable legal fees) as a result of claims by third parties to the

23 

 
 
 
 
CONFIDENTIAL 

proportionate extent arising out of or related to (a) the breach by Nevro of any of its warranties in 
Section  10.2  or  the    covenants  contained  in  Section  13  of  this  Agreement,  (b)  the  gross 
negligence or intentionally wrongful conduct of Nevro, (c) the storage, handling, modification, 
distribution,  marketing  or  sale  of  the  Nevro  System  and/or  any  of  the  Products  (including,  but 
not limited to, any design defects of the Product and any personal injury or death or other claims 
resulting from such design defects), but, for clarity, excluding any liability to the extent CCC is 
obligated to indemnify Nevro for such liability under Section 14.1 and any liability to the extent 
such  liability  arises  from  CCC’s  breach  of  this  Agreement,  (d)  any  statement,  promise, 
representation or warranty made by Nevro or by any agent or distributor of Nevro to a purchaser 
beyond  the  limited  warranty  made  by  CCC  in  this  Agreement,  (e)  any  and  all  Section  10.3(c) 
Causes  after  shipment  by  CCC,  (f)  materials,  Components,  directives  or  instructions  given  by 
Nevro to CCC, made in writing, (g) any failure to include warnings required by law or regulation 
on the Nevro System in which a  Product is incorporated  and any  recall of such Nevro  System 
that is not caused by CCC’s breach of this Agreement, and (h) infringement of the proprietary 
rights of any third party by Nevro Intellectual Property.  CCC shall promptly, and in any event, 
within thirty (30) days, after CCC first learns of such claim, notify Nevro of any claim under this 
section, tender the defense of such claim to Nevro (provided Nevro CCC diligently pursues such 
defense), and cooperate with Nevro at Nevro’s expense in connection with such defense. 

15. 
LIMITATION OF LIABILITY.  SUBJECT TO THE REMAINDER OF THIS SECTION 15, 
(A)  NEITHER  PARTY  WILL  BE  LIABLE  UNDER  THIS  AGREEMENT  FOR  ANY 
INDIRECT,  CONSEQUENTIAL,  COLLATERAL,  SPECIAL  OR  INCIDENTAL  DAMAGES 
(INCLUDING, BUT NOT LIMITED TO, LOSS OF PROFITS) WHETHER SUCH CLAIM IS 
BASED ON CONTRACT, NEGLIGENCE, STRICT TORT, WARRANTY OR ANY OTHER 
BASIS, AND (B) EACH PARTY’S TOTAL LIABILITY UNDER THIS AGREEMENT ([***]) 
WILL NOT EXCEED [***] FOR THE IMMEDIATELY PRECEDING [***] ([***]) MONTH 
PERIOD (INCLUDING ANY PORTION OF SUCH PERIOD PRECEDING THE EFFECTIVE 
DATE).    NOTWITHSTANDING  ANY  PAYMENTS  OF  DAMAGES  MADE  UNDER  THIS 
SECTION,  IF  CCC  BREACHES  THIS  AGREEMENT,  NEVRO  WILL  BE  ENTITLED  TO 
SPECIFIC PERFORMANCE AND THE LAST TIME BUY PURSUANT TO SECTION 11.7.  
THE  FOREGOING  LIMITATIONS  OF  LIABILITY  DO  NOT  APPLY  TO  A  PARTY’S 
INDEMNIFICATION  OBLIGATIONS  UNDER  SECTION  14.1  (PROVIDED  THAT  WITH 
RESPECT  TO  ANY  “OTHER  CLAIM”  DESCRIBED  IN  SECTION  14.1(i)(B),  CCC’S 
LIABILITY SHALL BE LIMITED TO AN AMOUNT EQUAL TO [***] THE AMOUNT OF 
THE  LIABILITY  LIMIT  DESCRIBED  ABOVE  IN  THIS  SECTION  15)  OR  SECTION  14.2, 
OR CONFIDENTIALITY OBLIGATIONS HEREUNDER.   

16. 

INSURANCE 

16.1  CCC Insurance.  CCC shall procure and maintain product liability insurance in 
such amounts as ordinary good business practice for its type of business would make advisable 
and shall provide Nevro with evidence of this coverage; provided, however, that in no case shall 
the  limits  of  such  coverage  be  less  than  the  following  (but  subject  to  any  deductible  or  self-
insured retention (SIR)): 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

24 

 
 
 
 
       
Bodily Injury:  

Property Damage: 

$[***] Each Occurrence 
$[***] General Aggregate 
$[***] Each Occurrence 
$[***] General Aggregate 

CONFIDENTIAL 

Upon  request,  CCC  shall  provide  Nevro  with  an  insurance  certificate  on  or  before 
January  31st  of  each  year  concerning  the  year  started  specifying  the  amounts  stated  in  this 
Section 16.1 including the SIR. 

16.2  Nevro Insurance.  Nevro shall procure and maintain product liability insurance 
in  such  amounts  as  ordinary  good  business  practice  for  its  type  of  business  would  make 
advisable and shall provide CCC with evidence of this coverage; provided, however, that in no 
case shall the limits of such coverage be less than the following (but subject to any deductible or 
self-insured retention (SIR)): 

Bodily Injury:  

Property Damage: 

$[***] Each Occurrence 
$[***] General Aggregate 
$[***] Each Occurrence 
$[***] General Aggregate 

Upon  request,  Nevro  shall  provide  CCC  with  an  insurance  certificate  on  or  before 
January  31st  of  each  year  concerning  the  year  started  specifying  the  amounts  stated  in  this 
Section 16.2 including the SIR. 

17.  GENERAL PROVISIONS 

17.1  Relationship  of  the  Parties.    The  parties  shall  perform  their  obligations  under 
this Agreement as independent contractors and nothing in this Agreement is intended or will be 
deemed  to  constitute  a  partnership,  agency  or  employer-employee  relationship  between  the 
parties.    Neither  party  will  have  any  right,  power  or  authority  to  assume,  create,  or  incur  any 
expense, liability, or obligation, express or implied, on behalf of the other. 

17.2  Assignments.  Subject to the remainder of this provision, this Agreement shall be 
binding upon, and shall inure to the benefit of, the parties’ respective successors and permitted 
assigns.  This Agreement shall not be assignable by either party without the prior written consent 
of the other party; provided, however, that, upon [***] ([***]) days prior written notice to CCC 
but  without  CCC’s  consent,  Nevro  (a)  may  assign  this  Agreement  to  any  of  its  Affiliates 
provided that Nevro shall remain  secondarily liable under this Agreement; and (b) shall assign 
this Agreement to any individual or entity which acquires all or substantially all of its assets to 
which this Agreement relates provided that the assignee, in the reasonable judgment of CCC, is 
able to perform Nevro’s obligations under this Agreement.  Any assignment not in accordance 
void. 
with 

Section 

17.2 

will 

null 

this 

and 

be 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONFIDENTIAL 

17.3  Further  Actions.   Each party agrees to  execute,  acknowledge, and deliver such 
further instruments and to do all such other lawful acts as may be reasonably necessary in order 
to carry out the express provisions of this Agreement. 

17.4  Headings;  Construction.    The  headings  to  the  clauses,  sub-clause  and  parts  of 
this Agreement are inserted for convenience of reference only and are not intended to be part of 
or to affect the meaning or interpretation of this Agreement.  Any ambiguity in this Agreement 
shall  be  interpreted  equitably  without  regard  to  which  party  drafted  the  Agreement  or  any 
provision  thereof.    The  terms  “this  Agreement,”  “hereof,”  “hereunder”  and  any  similar 
expressions refer to this Agreement and not to any particular Section or other portion hereof.  As 
used  in  this  Agreement,  the  words  “include”  and  “including,”  and  variations  thereof,  will  be 
deemed to be followed by the words “without limitation”.  

17.5  Governing  Law;  Arbitration.    This  Agreement  shall  be  governed  by  and 
construed  under  the  laws  of  the  State  of  Delaware,  U.S.A.,  without  regard  for  conflict  of  laws 
principles.  Any controversy or claim arising out of or relating to this Agreement, or its breach, 
shall be subject to binding arbitration in the State of Delaware, under the Commercial Arbitration 
Rules of the American Arbitration Association by three (3) arbitrators appointed in accordance 
with such Rules, provided, however, that neither party shall be precluded from seeking injunctive 
relief  or  other  provisional  relief  in  any  court  of  law.  The  language  of  the  arbitration  shall  be 
English. Judgment on the award rendered by the arbitrators may be entered in any court having 
jurisdiction. The parties expressly exclude the application of the United Nations Convention on 
Contracts for the International Sale of Goods.  It is not intended that any third party should be a 
beneficiary under this Agreement pursuant to the Contracts (Rights of Third Parties) Act 1999. 

17.6  Notices  and  Deliveries.    Any  notice,  request,  delivery,  approval  or  consent 
required or permitted to be given under this Agreement will be in writing and will be deemed to 
have  been  sufficiently  given  if  delivered  in  person  or  one  (1)  business  day  after  sending  by 
express  courier  service  (signature  required)  or  five  (5)  days  after  sending  by  registered  letter, 
return  receipt requested (or its equivalent), provided that no postal strike or other disruption is 
then in effect or comes into effect within two (2) days after such mailing, to the party to which it 
is directed at its address first shown above or as amended by notice pursuant to this subsection. 

17.7  Waiver.    A  waiver  by  a  party  of  any  of  the  terms  and  conditions  of  this 
Agreement  in  any  instance  will  not  be  deemed  or  construed  to  be  a  waiver  of  such  term  or 
condition  for  the  future,  or  of  any  subsequent  breach  thereof.    Unless  otherwise  expressly 
specified herein, all remedies contained in this Agreement will be cumulative and none of them 
will be in limitation of any other remedy. 

17.8  Severability.    Each  provision  of  this  Agreement  will  be  interpreted  in  such 
manner  as  to  be  effective  and  valid  under  Applicable  Law,  but,  if  any  provision  of  this 
Agreement is held to be prohibited by or invalid under Applicable Law, such provision will be 
ineffective  but  only  to  the  extent  of  such  prohibition  or  invalidity,  without  invalidating  the 
remainder of such provision or of this Agreement.  The parties will make a good faith effort to 
replace the invalid or unenforceable provision with a valid one which in its economic effect is 
most consistent with the invalid or unenforceable provision. 

26 

 
 
 
 
CONFIDENTIAL 

17.9  Counterparts.  This Agreement may be executed simultaneously in counterparts, 
including by facsimile or electronic exchange of signed copies in PDF format, any  one  of  which 
need not contain the signature of more than one party but both such counterparts taken together 
will constitute one and the same agreement. 

17.10  Entire  Agreement  of  the  Parties;  Conflicts.    This  Agreement,  the  Quality 
Agreement,  and  the  other  exhibits  hereto  constitute  and  contain  the  entire  understanding  and 
agreement of the parties respecting the subject matter hereof and cancels and supersedes any and 
all  prior  and  contemporaneous  negotiations,  correspondence,  understandings,  and  agreements 
between the parties, whether oral or written, regarding such subject matter.  In the event of any 
conflict between the provisions of this Agreement and the provisions of the Quality Agreement 
or any other exhibit hereto, the provisions of this Agreement shall govern. 

17.11  Amendments.  No waiver, modification, or amendment of any provision of this 

Agreement will be valid or effective unless made in writing and signed by each of the parties. 

17.12  Force  Majeure.  The  failure  or  delay  of  either  Party  to  perform  fully  any  of  its 
obligations under this Agreement (other than a payment obligation) solely by reason of acts of 
God;  acts  of  civil  or  military  authority;  civil  disturbance;  war;  embargo;  strikes  or  other  labor 
disputes  (excluding  those  related  to  a  party’s  workforce);  fire;  a  delay  or  default  caused  by 
common carriers; or similar circumstance beyond its reasonable control which cannot reasonably 
be  foreseen  or  provided  against  (“Force  Majeure”)  will  be  deemed  not  to  be  a  breach  of  this 
Agreement  so  long  as  the  party  so  prevented  from  complying  with  this  Agreement  has  not 
contributed to such Force Majeure, has used commercially reasonable efforts to avoid such Force 
Majeure  or  to  ameliorate  its  effects,  and  continues  to  take  all  commercially  reasonable  actions 
within its power to comply as fully as possible with the terms of this Agreement.  In the event of 
any such Force Majeure, full performance of the obligations affected will be deferred until the 
Force Majeure ceases.  This Section will not apply to excuse a failure to comply with the terms 
of this Agreement arising from any commercial dispute between a Party and a third party or the 
failure by a Party to secure any materials, supplies, labor or other input for any reason not caused 
by Force Majeure. 

[Remainder of page left intentionally blank.]

27 

 
 
 
 
 
 
 
 
IN  WITNESS  WHEREOF,  the  parties  have  caused  this  Agreement  to  be  executed  by  their 
respective duly authorized representatives as of the Effective Date. 

CONFIDENTIAL 

CENTRO DE CONSTRUCCION DE 
CARDIOESTIMULADORES DEL 
URUGUAY S.A. 

NEVRO CORP. 

By: /s/ Antonio Gonzalez 

By: /s/ Andrew Galligan 

Name: Antonia Gonzalez 

Name: Andrew Galligan 

Title: President, CRMN 

Title: Chief Financial Officer 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONFIDENTIAL 

Exhibit A 

Products 

For IPG 1500: 

PRODUCTS 

Minimum Purchase Thresholds 

Lead Time 

[***] 

[***] 

[***] 

[***] 

[***]  

[***] 

[***] 

[***] 

[***] 

[***] 

[***] 

[***] 

Contract Year One 

Contract Year Two 
and thereafter 

IPG Model 1500 VOLUME  

PRICE 

[***] 

[***] 

  [***] 

  [***] 

The prices in the table above reflect incremental volume pricing (for example, the 
price for the first [***] units in Contract Year one is [***] per unit and the price for 
the next [***] units is [***] per unit in that Contract Year).  The IPG volumes above 
are measured by the volumes of units ordered during a Contract Year (or at any time 
during 2016 for Contract Year 1).   

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
For IPG Model 2000: 

CONFIDENTIAL 

The following provisions are non-binding on the parties unless and until (a) [***], (b) [***], and 
(c) [***].  Both parties agree to update the lead time for IPG 2000 upon successful completion of 
the qualification and release to production.  Nevro shall reimburse CCC for its reasonable, 
documented IPG Model 2000 manufacturing startup cost up to the amount of non-recurring 
engineering fees set forth in the table below:  

IPG 2000 

Item 

Non-Recurring Engineering Fee Milestone Payment Schedule 

Milestone Price 

1 

NRE includes the following: 
[***] 
[***] 

[***] 
[***] 

[***] 
[***] 

[***] 
[***] 

$[***] 
$[***] 

$[***] 
$[***]-$[***] 

Once approvals and qualifications in items (a) through (c) have occurred, the following 
provisions shall apply to Nevro IPG Model 2000: 

Subject to the terms and conditions of the Agreement, Nevro commits to a Minimum Purchase 
Threshold of [***]% of the IPG Model 2000 worldwide requirements through the term of the 
Agreement.  Nevro’s Forecast provided on or about December 31 of each year shall include 
Nevro’s projected volume of Products and share commitment for the IPG Model 2000 Product 
for the following Contract Year.  Nevro’s price per Product for each IPG Model 2000 Product 
for such Contract Year shall be determined based upon such projected volume and share 
commitment in accordance with the following table: 

                                          IPG Model 2000 Price Table 

Price/Unit 

Product 
Units/Year 
[***] 
[***] 
[***] 
[***] 
[***] 

[***]%  Share 
Commitment 
$[***] 
$[***] 
$[***] 
$[***] 
$[***] 

[***]%  Share 
Commitment 
$[***] 
$[***] 
$[***] 
$[***] 
$[***] 

[***]%  Share 
Commitment 
$[***] 
$[***] 
$[***] 
$[***] 
$[***] 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONFIDENTIAL 

On or about September 1 of each Contract Year, the parties shall meet to review the next 
Contract Year Forecast and Nevro commitment and the per unit price for the Products for the 
next Contract Year will be determined using the initial forecasted volume’s price per the 
appropriate pricing tier set out above. If the forecasted volume is within [***]% of Products of 
the next tier’s volume break, the parties agree to set the initial pricing at the higher price (i.e., 
lower volume) and review such pricing twice per year for any material changes in the Forecast. 
A credit will be issued to Nevro immediately and the per unit price will be reset once shipments 
scheduled for delivery during the binding portion of the Forecast (pursuant to Section 2.1) 
exceed the current volume/pricing tier and subsequent Purchase Orders scheduled for delivery 
during the same Contract Year would be placed at the lower price (i.e., higher volume pricing 
tier.  In the event that Nevro purchases in any Contract Year an amount of Products which is less 
than the initial Forecast for such Contract Year and the total amount of Products purchased 
during such Contract Year is in a higher price tier than the price tier offered based on the initial 
Forecast for such Contract Year, Nevro shall make a payment to CCC, by the end of such 
Contract Year, an amount equal to [***]. 

Certain Price Adjustments.  If Nevro agrees to purchase from CCC or any of its Affiliates a 
minimum of [***] percent ([***]%) of its finished leads products in for a Contract Year, Nevro 
shall receive an additional [***] percent ([***]%) reduction in price for each IPG Model 2000 
Product ordered in accordance with such Forecast.  Additionally, if Nevro agrees to utilize CCC- 
or an CCC Affiliate-manufactured battery, feedthrough and enclosure Components in any 
Contract Year, Nevro shall receive at least a [***] dollar ($[***]) reduction in price for each IPG 
Model 2000 Product ordered in accordance with such Forecast.  If Nevro agrees to utilize any 
one of the CCC- or CCC Affiliate-[***] in any Forecast, the parties will negotiate an applicable 
reduction in price for each IPG Model 2000 Product ordered in accordance with such Forecast. 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

 
 
 
 
CONFIDENTIAL 

Exhibit B 

Specifications 

IPG Model 1500 

Document Number 

Description 

[***] 

[***] 

[***] 

[***] 

IPG Model 2000 

Document Number 

Description 

[***] 

[***] 

[***] 

[***] 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

 
 
 
 
 
 
 
Exhibit C 

CCC Change Notice Form 

CONFIDENTIAL 

[Intentionally omitted.] 

 
 
 
 
 
Exhibit D 

Program Team List 

E-mail Address 
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 

Phone Number 
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 

CONFIDENTIAL 

Title/Responsibility 
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 

Phone Number 

E-mail Address 
[***] 

Title/Responsibility 
[***] 

[***] 
[***] 
[***] 
 [***] 
[***] 

[***] 
[***] 
 [***] 
[***] 

[***] 
[***] 
 [***] 
[***] 

CCC: 

Name   
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 

Nevro: 

Name   
[***] 

[***] 
[***] 
[***] 
[***] 

Communication Counterparts: 

Topics 
[***] 

[***] 
[***] 
[***] 

[***] 

[***] 
[***] 

[***] 

[***] 
[***] 

[***] 
[***] 
[***] 

CCC Representatives 

Nevro Representatives 

[***] 
[***] 

[***] 
[***] 
[***] 

[***] 
[***] 
[***] 
[***] 
[***] 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit E 

Approved Facility; Facilities Transfer 

CONFIDENTIAL 

Approved Facility: 
[***] 

[***]

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

 
 
 
 
For IPG 1500: 

Component  
[***]  
[***]  

Supplier 
[***]  
[***]  

Cost  
[***] 
[***] 

[***]  
[***]  
[***]  
[***]  
[***]  
[***]  
[***]  
[***] 
[***] 
[***] 
[***] 
[***]  

[***] 
[***]  

TOTAL  

[***]  
[***]  
[***]  
[***]  
[***]  
[***]  
[***]  
[***] 
[***] 
[***] 
[***] 

[***]  
[***]  
[***]  

Exhibit F 

Bill of Materials 

Qty  
[***]  
[***]  

[***]  
[***]  
[***]  
[***]  
[***]  
[***]  
[***]  
[***] 
[***] 
[***] 
[***] 

[***]  

[***] 
[***] 
[***] 
[***]  
[***]  
[***] 
[***] 
[***] 
[***] 
[***] 
[***] 

[***]  

[***] 

[***]  

Total cost  
[***] 
[***] 

[***] 
[***] 
[***]  
[***]  
[***] 
 [***] 
[***] 
[***] 
[***] 
[***] 
[***] 

[***]  
[***]  
 [***]  

[***] 

For IPG 2000:  [***] 

[***] 

[***] Certain information has been omitted and filed separately with the Securities and Exchange 
Commission. Confidential treatment has been requested with respect to the omitted portions. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 10.23(b) 

FIRST AMENDMENT TO LEASE 
(EXPANSION) 

This First Amendment to Lease (the "Agreement") is entered into as of December 9, 

2016, by and between WESTPORT OFFICE PARK, LLC, a California limited liability 
company ("Landlord"), and NEVRO CORP., a Delaware corporation ("Tenant"), with respect 
to the following facts and circumstances: 

A. 

Landlord and Tenant are parties to that certain Lease Agreement dated 

March 5, 2015 (the "Original Lease") of certain premises (the "Existing Premises") within the 
building commonly known as 1800 Bridge Parkway, Redwood City, California 94065 (the 
"1800 Bridge Building"), and more particularly described in the Original Lease.  Capitalized 
terms used and not otherwise defined herein shall have the meanings given those terms in the 
Original Lease. Effective as of the date hereof, all references to the "Lease" shall refer to the 
Original Lease, as amended by this Agreement. 

B. 

Landlord and Tenant desire to amend the Original Lease to add additional 

space on the terms and conditions provided herein.   

IT IS, THEREFORE, agreed as follows: 

1. 

As used in this Agreement, the following terms have the following meanings: 

"Expansion Space" means the entire building commonly known as 1600 

Bridge Parkway, Redwood City, California 94065 (the "1600 Bridge Building"), containing 
approximately 49,981 rentable square feet of area, and more particularly shown on 
Exhibit "B-1" attached hereto. 

"Expansion Space Commencement Date" shall mean the date that is the earlier 
of (i) the date Tenant commences business operations in the Expansion Space, or (ii) the date 
of Substantial Completion (as defined in the Tenant Work Letter attached hereto as 
Exhibit "C-1") of the Expansion Space.  

2. 

Effective on the Expansion Space Commencement Date, the Premises shall be 

expanded to include the Expansion Space.  Accordingly, effective on the Expansion Space 
Commencement Date, Landlord leases the Expansion Space to Tenant and Tenant leases the 
Expansion Space from Landlord, and the following terms of the Original Lease are amended 
as follows: 

2.1 

The Expansion Space is added to the Premises such that the Premises 

shall be comprised of the Existing Premises and the Expansion Space, and Exhibit "B-1" 
attached hereto is hereby added to Exhibit "B" to the Original Lease. 

2.2 

Tenant's Building Percentage and Tenant's Tax Percentage with respect 

to the 1600 Bridge Building is 100%. Tenant's Common Area Building Percentage is 
increased to 10.07%. 

-1- 

 
 
 
 
 
2.3 

Tenant agrees to pay Landlord a monthly Base Rent for the Expansion 

Space in accordance with the following schedule: 

Period 
(In Months) 

01 – 12 
13 – 15 
16 – 24 
25 – 36 
37 – 48 
49 – 60 
61 – 72 
72 – 84 

Annual Base Rent 

Monthly Base Rent 

$1,199,544.00* 
$1,235,530.32* 
$2,471,060.64 
$2,545,192.44 
$2,621,548.20 
$2,700,194.64 
$2,781.200.52 
$2,864,636.52 

$99,962.00* 
$102,960.86* 
$205,921.72 
$212,099.37 
$218,462.35 
$225,016.22 
$231,766.71 
$238,719.71 

      *  As an inducement to Tenant entering into this Agreement, during the first fifteen (15) 
months after the Expansion Space Commencement Date, so long as no Event of 
Default shall have occurred under the Lease, for purposes of calculating Base Rent 
only, the Expansion Space shall be deemed to contain only 24,990.50 square feet of 
rentable area.  The amount of Base Rent for the Expansion Space set forth in the table 
in this Section 2.3 for that period reflects that deemed square footage. During such 
abatement period, Tenant shall still be responsible for the payment of all of its other 
monetary obligations under the Lease. The amount equal to the difference between 
Base Rent payable based on that deemed square footage and the Base Rent that would 
be payable if the actual square footage of the Expansion Space were used is referred to 
herein as the "Rental Abatement." In the event of a default by Tenant under the terms 
of the Lease that results in early termination pursuant to the provisions of Article 22 of 
the  Lease, then as part of the recovery set forth in Article 22 of the Lease, Landlord 
shall be entitled to the recovery of the Rental Abatement. 

The monthly Base Rent for the Expansion Space for the first month after the Expansion Space 
Commencement Date shall be payable upon the execution of this Agreement.  The monthly 
Base Rent for the Expansion Space shall be payable in the manner provided for in the 
Original Lease. 

2.4 

The Term with respect to the Expansion Space shall be coterminous 

with the Existing Premises, as extended by this Agreement.  In the event that Tenant exercises 
an extension option pursuant to the Original Lease or the Original Lease terminates pursuant 
to its terms, such extension or termination shall apply to the entire Premises then subject to 
the Original Lease (including the Expansion Space). 

Tenant's Parking Allocation shall be increased from one hundred 
sixty-six (166) non-exclusive parking spaces to three hundred thirty (330) non-exclusive 

2.5 

-2- 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
parking spaces, which is based on a parking ratio of 3.3 non-exclusive parking spaces per one 
thousand (1,000) square feet of rentable space in the Premises. 

2.6 

The provisions of Section 32.2 of the Original Lease shall apply 

independently to each of the 1600 Bridge Building and the 1800 Bridge Building such that 
Tenant shall have the right to install Monument Signage and Building-top Signage on each of 
those buildings , subject to the terms and conditions of Section 32.2 of the Original Lease (as 
amended hereby), except that the right to install and maintain Monument Signage on the 
monument sign and Building-top Signage at the top of the 1600 Bridge Building shall 
permanently terminate upon written notice from Landlord following the date upon which 
Tenant ceases to occupy at least one full floor of the 1600 Bridge Building.  Accordingly, for 
purposes of interpreting that Section, each reference to "Building" shall be a reference to each 
of the 1600 Bridge Building and the 1800 Bridge Building.  Landlord hereby (a) approves the 
graphics, materials, color, design, lettering size, placement and specifications and conformity 
with Landlord's sign plan of the Building-top Signage to be installed on the 1600 Bridge 
Building substantially in the form shown on Exhibit "D" attached hereto, and (b) agrees that 
Tenant may change the color of the existing Building-top Signage on the 1800 Bridge 
Building to substantially the same color as shown on Exhibit "D" attached hereto.  

2.7 

Except as otherwise expressly provided in this Agreement, all 

references to the "Building" in the Lease shall refer to the 1600 Bridge Building and the 
1800 Bridge Building, either collectively or individually, as the context requires. 

3. 

Tenant may take possession of the Expansion Space upon the delivery of 

possession of the Expansion Space by Landlord to Tenant.  Tenant's possession of the 
Expansion Space prior to the Expansion Space Commencement Date shall be on all the terms 
and conditions of the Original Lease, as amended hereby, except that Tenant shall not be 
obligated to pay Base Rent or Tenant's Share of Operating Expenses.  After the Expansion 
Space Commencement Date, Tenant's obligation with respect to Base Rent and Tenant's Share 
of Operating Expenses shall be as provided in the Original Lease, as amended by this 
Agreement.  Tenant shall accept the Expansion Space in its "AS IS" condition and Tenant 
agrees that Landlord has no obligation and has made no promise to alter, remodel, improve, or 
repair the Expansion Space, or any part thereof, or to repair, bring into compliance with 
applicable laws, or improve any condition existing in the Expansion Space as of the 
Expansion Space Commencement Date, except as provided for in the Tenant Work Letter 
attached hereto as Exhibit "C-1"; provided nothing in this sentence shall limit Landlord's 
ongoing obligations under the Lease with respect to repairs, restoration and maintenance.  
Except as set forth herein, neither Landlord nor Landlord's agents have made any 
representations or promises with respect to the condition of the 1600 Bridge Building, the 
Expansion Space, the land upon which the 1600 Bridge Building is constructed, the present or 
future suitability or fitness of the Expansion Space or the 1600 Bridge Building for the 
conduct of Tenant's particular business, or any other matter or thing affecting or related to the 
1600 Bridge Building or the Expansion Space, and no rights, easements or licenses are 
acquired by Tenant by implication or otherwise except as expressly set forth in this 
Agreement.  Any improvements or personal property located in the Expansion Space are 
delivered without any representation or warranty from Landlord, either express or implied, of 
any kind, including without limitation, title, merchantability, or suitability for a particular 

-3- 

 
 
 
 
 
 
 
 
purpose.  Tenant shall deliver to Landlord any modifications to Tenant's insurance required 
under the Original Lease to reflect the addition of the Expansion Space and Tenant's entry 
into the Expansion Space prior to the delivery of possession to Tenant.  Without limiting the 
Landlord's obligations set forth in Section 4 below, Landlord shall not be liable to Tenant or 
otherwise be in default hereunder in the event that Landlord is unable to deliver the Expansion 
Space to Tenant on the projected delivery date thereof due to the failure of any other tenant to 
timely vacate and surrender to Landlord such Expansion Space, or any portion thereof; 
provided, however, Landlord agrees to use its commercially reasonable efforts to enforce its 
rights to possession of such Expansion Space against such tenant (including by bringing suit 
to evict or otherwise dispossess such tenant of the Expansion Space). 

4. 

Temporary Space. 

4.1 

In the event that delivery of possession of the Expansion Space to 

Tenant does not occur by the Temporary Space Date (as defined below), then Landlord shall 
use commercially reasonable efforts to provide Tenant with temporary space in the Project 
that is Available for Temporary Use (as defined below) containing rentable area of at least 
4,000 square feet.  Any space occupied by Tenant pursuant to this Section 4 is referred to in 
this Section 4 as the "Temporary Space."  As used in this Section 4, "Available for Temporary 
Use" means that the space (i) is not occupied by any person, (ii) may be lawfully occupied 
without the expenditure of additional funds, (iii) is not then subject to a lease, (iv) is not then 
subject to any rights of any tenant to renew their lease or expand their premises as set forth in 
their lease for the period during which Tenant would occupy such space, (v) is not then 
subject to any negotiations between Landlord and a prospective tenant or an existing tenant, 
and (vi) is not located in the building known as 1200 Bridge Parkway, Redwood City, 
California.  The term "Temporary Space Date" initially means December 1, 2017, but shall be 
extended by one day for every one day in delay caused by any one or more Force Majeure 
Events. 

4.2 

If Landlord identifies Temporary Space and Tenant elects to occupy the 

Temporary Space, then during the period beginning on the delivery of possession of the 
Temporary Space to Tenant and ending on the date that is five (5) days after the earlier of 
(a) Expansion Space Commencement Date, and (b) if applicable, the date upon which Tenant 
gives Landlord notice of termination of this Agreement pursuant to Section 6, below (such 
period being referred to herein as the "Temporary Space Term"), Landlord shall allow Tenant 
to use the Temporary Space for the uses permitted by the Lease.  During the Temporary Space 
Term, the Temporary Space shall be deemed part of the "Premises".  Such Temporary Space 
shall be accepted by Tenant in its "as-is" condition and configuration, it being agreed that 
Landlord shall be under no obligation to perform any work in the Temporary Space or to 
incur any costs in connection with Tenant's move in, move out or occupancy of the 
Temporary Space.  Tenant acknowledges that it shall be entitled to use and occupy the 
Temporary Space at its sole cost, expense and risk.  Tenant shall not construct any 
improvements or make any alterations of any type to the Temporary Space without the prior 
written consent of Landlord, which shall not be unreasonably withheld, conditioned or 
delayed.  All actual out-of-pocket of Landlord and any costs of Tenant in connection with 
making the Temporary Space ready for occupancy by Tenant shall be the sole responsibility 
of Tenant. 

-4- 

 
 
 
 
 
 
 
 
4.3 

The Temporary Space shall be subject to all the terms and conditions of 

the Lease except as expressly modified in this Section 4, provided that Tenant shall not be 
obligated to pay Base Rent during the Temporary Space Term with respect to the Temporary 
Space.  Tenant shall not be entitled to receive any allowances, abatement or other financial 
concession in connection with the Temporary Space which was granted with respect to the 
Premises or the Expansion Space unless such concessions are expressly provided for herein 
with respect to the Temporary Space, and the Temporary Space shall not be subject to any 
renewal or expansion rights of Tenant under the Lease. 

4.4 

Upon termination of the Temporary Space Term, Tenant shall vacate 

the Temporary Space and deliver the same to Landlord in the same condition that the 
Temporary Space was delivered to Tenant, ordinary wear and tear excepted and damage by 
casualty excepted.  At the expiration or earlier termination of the Temporary Space Term, 
Tenant shall remove all debris, all items of Tenant's personalty, and any trade fixtures of 
Tenant from the Temporary Space.  Tenant shall be fully liable for all damage Tenant or 
Tenant's agents, employees, contractors, or subcontractors cause to the Temporary Space, 
ordinary wear and tear excepted and damage by casualty excepted. 

4.5 

Tenant shall have no right to hold over or otherwise occupy the 

Temporary Space at any time following the expiration or earlier termination of the Temporary 
Space Term, and in the event of such holdover, Landlord shall immediately be entitled to 
institute dispossessory proceedings to recover possession of the Temporary Space, without 
first providing notice thereof to Tenant.  In the event of holding over by Tenant after 
expiration or termination of the Temporary Space Term without the written authorization of 
Landlord, Tenant shall pay, for such holding over, an amount equal to $7.80 per rentable 
square foot of the rentable area of the Temporary Space each month or partial month of 
holdover, plus all consequential damages that Landlord incurs as a result of the Tenant's hold 
over after the date that is the later of (a) the expiration or earlier termination of the Temporary 
Space Term, or (b) the date that is ten (10) days after Landlord has notified Tenant that 
Landlord has executed a letter of intent or lease with another tenant for all or any portion of 
the Temporary Space.  During any such holdover, Tenant's occupancy of the Temporary 
Space shall be deemed that of a tenant at sufferance, and in no event, either during the 
Temporary Space Term or during any holdover by Tenant, shall Tenant be determined to be a 
tenant-at-will under applicable law.  While Tenant is occupying the Temporary Space, 
Landlord or Landlord's authorized agents shall be entitled to enter the Temporary Space, upon 
reasonable notice, to display the Temporary Space to prospective tenants.  Tenant's 
obligations under this Section 5 shall survive the termination of this Agreement pursuant to 
Section 6, below. 

5. 

Notwithstanding Section 3 above, Landlord warrants that the roof, structural 
components of the 1600 Bridge Building, HVAC system, electrical and plumbing systems, 
elevator, parking lot and site lighting (the "Covered Items"), other than those constructed by 
Tenant, shall be in good operating condition and repair on the date possession of the 
Expansion Space is delivered to Tenant.  If a non-compliance with such warranty exists as of 
the delivery of possession, or if one of such Covered Items should malfunction or fail within 
ninety (90) days after the delivery of possession to Tenant, Landlord shall, as Landlord's sole 
obligation with respect to such matter, promptly after receipt of written notice from Tenant 

-5- 

 
 
 
 
 
 
 
 
setting forth in reasonable detail the nature and extent of such non-compliance, malfunction or 
failure, rectify the same at Landlord's expense.  If Tenant does not give Landlord the required 
notice within ten (10) days after the expiration of such ninety (90) day period, Landlord shall 
have no obligation with respect to that warranty other than obligations regarding the Covered 
Items set forth elsewhere in the Lease.  Any replacement of the roof or HVAC system during 
the Term shall be amortized as provided in Section 5.1(a)(vii) of the Original Lease. 

6. 

In the event that delivery of possession of the Expansion Space to Tenant does 
not occur by the Scheduled Delivery Date (as defined below), then Tenant shall be entitled by 
notice in writing to Landlord within ten (10) days thereafter to terminate this Agreement, in 
which event the parties shall be discharged from all obligations hereunder; provided further, 
however, that if such written notice of Tenant is not delivered to Landlord within such 
ten (10)-day period, Tenant's right to terminate this Agreement hereunder shall terminate and 
be of no further force or effect. If Tenant elects to terminate this Agreement under this Section 
then such termination of this Agreement shall be effective on the date which is thirty (30) 
days after delivery of notice of termination to Landlord.  In the event that this Agreement is 
terminated under this Section, then all of the terms and conditions of the Original Lease shall 
continue to apply.  The term "Scheduled Delivery Date" initially means June 1, 2018, but 
such date shall be extended by one day for each day in delay caused by any one or more Force 
Majeure Events or Tenant Delays (as defined in Exhibit "C-1"). 

7. 

Landlord and Tenant acknowledge that Tenant may desire to make certain 
alterations to the Existing Premises in accordance with Article 15 of the Lease ("Tenant's 
Work").  So long as no Event of Default shall be existing under the Original Lease (as 
amended by this Agreement) as of the date Tenant requests reimbursement of the Allowance 
(as defined below), Landlord agrees to reimburse Tenant up to, and not to exceed the sum of 
Three Hundred Fifty-Three Thousand Two Hundred Ninety Dollars ($353,290.00) (the 
"Allowance") (based on a $7.00 prsf of the Existing Premises).  Landlord shall pay the 
Allowance to Tenant upon delivery to Landlord of "Tenant's Completion Notice" (as defined 
below) according to the terms and conditions of this Section.  The Allowance shall be used to 
reimburse Tenant for hard and/or soft costs incurred in connection with Tenant's Work 
("Tenant's Work Costs"); provided, however, in no event shall the Allowance be used to pay 
for any of Tenant's trade fixtures, equipment or inventory.  Upon the completion of Tenant's 
Work, Tenant shall submit to Landlord a written notice indicating that Tenant has completed 
the construction and performance of Tenant's Work in accordance with the provisions of 
Article 15 of the Original Lease, as amended by this Agreement, which notice shall be 
accompanied by all of the following (collectively, "Tenant's Completion Notice"):  (i) copies 
of paid invoices and final, unconditional lien waivers (in the form required by applicable 
laws) from Tenant's general contractor and all subcontractors and material suppliers, showing 
that full payment has been received for the construction of Tenant's Work; (ii) certification 
from Tenant's architect that all of Tenant's Work has been completed substantially in 
accordance with the plans and specifications therefor (approved by Landlord, to the extent 
Landlord's approval of such plans and specifications was required under Article 15 of the 
Original Lease, as amended by this Agreement) and all local governmental and quasi-
governmental authorities with jurisdiction; and (iii) a copy of the building permit for Tenant's 
Work, if applicable, signed by the appropriate building inspector, indicating that Tenant's 

-6- 

 
 
 
 
 
 
 
 
Work has been finally approved.  The Allowance shall be available for a single 
reimbursement to Tenant during the period from the Expansion Space Commencement Date 
through the date that is twelve (12) months after the Expansion Space Commencement Date 
(the "Window").  Any portion of the Allowance not requested by Tenant within the Window 
shall be deemed forfeited by Tenant and shall no longer be available for disbursement to or 
for the account of Tenant. In lieu of using some or all of the Allowance for Tenant's Work, so 
long as no Event of Default then exists under the Lease (other than a default in payment of 
Base Rent that would be fully cured by the requested application of the Allowance), Tenant 
may elect to apply the Allowance to payment of Base Rent, first coming due after the 
Expansion Space Commencement Date by written notice to Landlord. 

8. 

The "Expiration Date" as defined in the Original Lease is hereby amended to 
be the date that is the day prior to the day that is eighty-four (84) months after the Expansion 
Space Commencement Date (the "New Expiration Date"), subject to the terms set forth in this 
Section 8.  If the New Expiration Date falls on a day other than the last day of the calendar 
month, then, the New Expiration Date shall be deemed to be the last day of such calendar 
month and the Term of the Lease shall be deemed to expire on such date. The period from 
July 1, 2022 (the "Extension Commencement Date") to the New Expiration Date is referred to 
herein as the "Extension Term." 

9. 

Prior to the Extension Commencement Date, Tenant shall continue to pay to 
Landlord monthly Base Rent for the Existing Premises in accordance with the terms of the 
Original Lease. Commencing on the Extension Commencement Date, Tenant shall pay to 
Landlord monthly Base Rent for the Existing Premises at the same rental rate per square foot 
of rentable area then in effect for the Expansion Space, as the rental rate for monthly Base 
Rent for the Expansion Space may increase from time to time.   

10. 

Tenant is in occupancy of the Existing Premises and will accept the same, as of 

the commencement of the Extension Term in its "as is" condition, without any agreements, 
representations, understandings or obligations on the part of Landlord to (i) perform any 
alterations, additions, repairs or improvements therein, (ii) fund or otherwise pay for any 
alterations, additions, repairs or improvements thereto, or (iii) grant Tenant any free rent, 
concessions, credits or contributions of money with respect to the Premises, except as may be 
expressly provided otherwise in this Agreement.  Nothing in this Section 10 shall limit 
Landlord's ongoing obligations under the Lease with respect to repairs, restoration and 
maintenance.   

11. 

The Extension Option in Article 51 of the Original Lease shall continue to 

apply during the Extension Term, except that the term "initial Lease Term" shall be replaced 
with "Extension Term" each place it appears in Article 51. 

12. 

Except as otherwise provided herein, all of the terms and conditions of the 

Original Lease shall continue to apply during the Extension Term; provided, however, that 
any provisions of the Original Lease with respect to rent credit, improvement allowances, 
Landlord construction obligations or other initial concessions shall be inapplicable with 
respect to the Extension Term. 

-7- 

 
 
 
 
 
 
 
 
13. 

Landlord hereby represents and warrants to Tenant that it has dealt with no 

broker, finder or similar person in connection with this Agreement, and Tenant hereby 
represents and warrants to Landlord that it has dealt with no broker, finder or similar person in 
connection with this Agreement, other than Cushman & Wakefield ("Landlord's Broker") and 
Jones Lang LaSalle Brokerage, Inc. ("Tenant's Broker").  Landlord and Tenant shall each 
defend, indemnify and hold the other harmless with respect to all claims, causes of action, 
liabilities, losses, costs and expenses (including without limitation attorneys' fees and 
disbursements) with respect to any leasing commission or equivalent compensation alleged to 
be owing on account of the indemnifying party's dealings with any real estate broker, agent, 
finder or similar person other than Landlord's Broker  and Tenant's Broker.  The commission 
with respect to this Agreement shall be paid to Landlord's Broker by Landlord pursuant to a 
separate agreement.  Landlord's Broker will pay Tenant's Broker a commission pursuant to a 
separate agreement.  Nothing in this Agreement shall impose any obligation on Landlord to 
pay a commission or fee to any party other than Landlord's Broker. 

14. 

As additional consideration for this Agreement, Tenant hereby certifies that: 

(a) 

The Original Lease (as amended hereby) is in full force and 

effect. 

(b) 

Tenant is in possession of the Existing Premises and has not 

sublet any portion of the Existing Premises or assigned its interest in the Lease 

(c) 

To Tenant's knowledge, there are no uncured defaults on the 

part of Landlord or Tenant under the Original Lease. 

(d) 

All of Landlord's obligations with respect to construction of 

tenant improvements in the Premises and payment of tenant improvement allowances 
have been satisfied, except those provided for in the Tenant Work Letter attached 
hereto as Exhibit "C-1." 

There are no existing offsets or defenses which Tenant has 
against the enforcement of the Original Lease (as amended hereby) by Landlord. 

(e) 

15. 

Except as specifically provided herein, the terms and conditions of the Original 

Lease as amended hereby are confirmed and continue in full force and effect.  This 
Agreement shall be binding on the heirs, administrators, successors and assigns (as the case 
may be) of the parties hereto.  This Agreement and the attached exhibits, which are hereby 
incorporated into and made a part of this Agreement, together with the Original Lease, set 
forth the entire agreement between the parties with respect to the matters set forth herein.  
There have been no additional oral or written representations or agreements.  Under no 
circumstances shall Tenant be entitled to any Rent abatement, improvement allowance, 
leasehold improvements, or other work to the Premises, or any similar economic incentives 
that may have been provided to Tenant in connection with entering into the Original Lease, 
unless specifically set forth in this Agreement.  Tenant agrees that neither Tenant nor its 
agents or any other parties acting on behalf of Tenant shall disclose any matters set forth in 
this Agreement or disseminate or distribute any information concerning the terms, details or 

-8- 

 
 
 
 
 
 
 
 
conditions hereof to any person, firm or entity without obtaining the express written consent 
of Landlord.  In the case of any inconsistency between the provisions of the Original Lease 
and this Agreement, the provisions of this Agreement shall govern and control.  Submission 
of this Agreement by Landlord is not an offer to enter into this Agreement but rather is a 
solicitation for such an offer by Tenant.  Landlord shall not be bound by this Agreement until 
Landlord has executed and delivered the same to Tenant.  Time is of the essence of this 
Agreement and the provisions contained herein. 

16. 

As an inducement to Landlord to enter into this Agreement, Tenant hereby 

represents and warrants that:  (i) Tenant is not, nor is it owned or controlled directly or 
indirectly by, any person, group, entity or nation named on any list issued by the Office of 
Foreign Assets Control of the United States Department of the Treasury ("OFAC") pursuant 
to Executive Order 13224 or any similar list or any law, order, rule or regulation or any 
Executive Order of the President of the United States as a terrorist, "Specially Designated 
National and Blocked Person" or other banned or blocked person (any such person, group, 
entity or nation being hereinafter referred to as a "Prohibited Person"); (ii) Tenant is not (nor 
is it owned or controlled, directly or indirectly, by any person, group, entity or nation which 
is) acting directly or indirectly for or on behalf of any Prohibited Person; and (iii) neither 
Tenant (nor any person, group, entity or nation which owns or controls Tenant, directly or 
indirectly) has conducted or will conduct business or has engaged or will engage in any 
transaction or dealing with any Prohibited Person, including without limitation any 
assignment of the Lease or any subletting of all or any portion of the Premises or the making 
or receiving of any contribution of funds, goods or services to or for the benefit of a 
Prohibited Person.  Tenant covenants and agrees (a) to comply with all requirements of law 
relating to money laundering, anti-terrorism, trade embargos and economic sanctions, now or 
hereafter in effect, (b) to immediately notify Landlord in writing if any of the representations, 
warranties or covenants set forth in this Section are no longer true or have been breached or if 
Tenant has a reasonable basis to believe that they may no longer be true or have been 
breached, (c) not to use funds from any Prohibited Person to make any payment due to 
Landlord under the Lease and (d) at the request of Landlord, to provide such information as 
may be reasonably requested by Landlord to determine Tenant's compliance with the terms 
hereof.  Any breach by Tenant of the foregoing representations and warranties shall be 
deemed a default by Tenant under this Lease and shall be covered by the indemnity provisions 
of the Original Lease.  The representations and warranties contained in this Section shall be 
continuing in nature and shall survive the expiration or earlier termination of the Lease. 

17. 

To satisfy compliance with the Employee Retirement Income Security Act of 

1974, as amended ("ERISA"), and Section 4975(c) of the Internal Revenue Code, Tenant 
hereby certifies that the representations and warranties in Article 53 of the Original Lease are 
true and correct as of the date of this Agreement. 

18. 

Pursuant to California Civil Code Section 1938, Tenant is hereby notified that, 

as of the date hereof, the 1600 Bridge Building and the 1800 Bridge Building have not 
undergone an inspection by a "Certified Access Specialist" and Landlord states the following: 
"A Certified Access Specialist (CASp) can inspect the subject premises and determine 
whether the subject premises comply with all of the applicable construction-related 
accessibility standards under state law. Although state law does not require a CASp inspection 

-9- 

 
 
 
 
 
 
 
 
of the subject premises, the commercial property owner or lessor may not prohibit the lessee 
or tenant from obtaining a CASp inspection of the subject premises for the occupancy or 
potential occupancy of the lessee or tenant, if requested by the lessee or tenant. The parties 
shall mutually agree on the arrangements for the time and manner of the CASp inspection, the 
payment of the fee for the CASp inspection, and the cost of making any repairs necessary to 
correct violations of construction-related accessibility standards within the premises."  
Landlord makes no representations as to the compliance of the Premises, the 1600 Bridge 
Building or the 1800 Bridge Building with accessibility standards.  Notwithstanding anything 
contained herein or in the Original Lease to the contrary, Tenant shall not be responsible for 
compliance with the path of travel provisions of the Americans with Disabilities Act at any 
time during the Term (including any extension thereof) except for any compliance work 
required with reference to the particular use of Tenant (other than general office use), the acts 
or omissions of Tenant or any of Tenant's agents, employees, contractors, sublessees or 
invitees, or any alterations, additions or improvements performed by or on behalf of Tenant 
(other than the Expansion Space Improvements).  

-10- 

 
 
 
 
 
 
 
 
IN WITNESS WHEREOF, this Agreement was executed as of the date first above 

written. 

Landlord: 

WESTPORT OFFICE PARK, LLC, 
a California limited liability company 

 By:    THE PRUDENTIAL INSURANCE 
COMPANY OF AMERICA, a New  
Jersey corporation, acting solely on behalf 
of and for the benefit of, and with its 
liability limited to the assets of, its 
insurance company separate account, 
PRISA II, its member 

/s/ Jeffrey D. Mills 
Jeffrey D. Mills 
Vice President 
[Printed Name and Title] 

   By:

Tenant: 

NEVRO CORP., a Delaware corporation 

 By:  

/s/ Andrew Galligan 

Its:

Chief Financial Officer 

By:

/s/ Richard B. Carter 

Its:

VP Finance 

If Tenant is a corporation, this instrument must  
be executed by the chairman of the board, the 
president or any vice president and the secretary, 
any assistant secretary, the chief financial officer 
or any assistant financial officer or any assistant 
treasurer of such corporation, unless the bylaws 
or a resolution of the board of directors shall 
otherwise provide, in which case the bylaws or a 
certified copy of the resolution, as the case may 
be, must be attached to this instrument.  

-11- 

 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
  
  
  
  
  
  
 
 
 
  
  
  
 
  
  
 
  
  
 
  
  
 
 
EXHIBIT B-1 

EXPANSION SPACE 

(See Attached.) 

Exhibit B-1 

 
 
 
 
 
 
 
 
 
 
 
EXHIBIT C-1 

TENANT WORK LETTER 

This Tenant Work Letter is attached to and made a part of that certain First 
Amendment to Lease dated December 9, 2016 (the "Amendment") between WESTPORT 
OFFICE PARK, LLC, a California limited liability company ("Landlord"), and NEVRO 
CORP., a Delaware corporation ("Tenant"), which amends the Original Lease (as defined in 
the Amendment).  Any capitalized term used and not otherwise defined in this Tenant Work 
Letter has the meaning given such term in the Amendment (or, if not defined in the 
Amendment, the meaning given such term in the Original Lease).  This Tenant Work Letter 
sets forth the terms and conditions relating to the construction of the Expansion Improvements 
in the Expansion Space.   

Section 1 

BASE, SHELL AND CORE; LANDLORD WORK 

1.1 

Base, Shell and Core.  Landlord has previously constructed the base, 

shell, and core (i) of the Expansion Space and (ii) of the floor(s) of the Building on which the 
Expansion Space are located (collectively, the "Base, Shell, and Core") and other 
improvements, and Tenant shall accept the Base, Shell and Core and such other improvements 
in their current "As-Is" condition existing as of the date of the Amendment and the Expansion 
Space Commencement Date. Tenant shall install in the Expansion Space certain "Expansion 
Space Improvements" (as defined below) pursuant to the provisions of this Tenant Work 
Letter.  Except for Landlord's obligation to disburse the Expansion Space Improvement 
Allowance and perform the Landlord Work and the Expansion Space Improvement work as 
described below, Landlord shall not be obligated to make or pay for any alterations or 
improvements to the Expansion Space, the Premises, the Building or the Project.  

1.2 

Landlord Work.  As a condition to the delivery of possession of the 

Expansion Space to Tenant, Landlord shall satisfy the following conditions at Landlord's sole 
cost and expense (the "Landlord's Work"): 

reasonably approved by Landlord; and  

(a)   install one (1) new electric car charging station in a location 

(b)  correct any failure of the path of travel for the Expansion Space 

outside of the 1600 Bridge Building to comply with the Americans with Disabilities Act, as 
interpreted by the City of Redwood City and Landlord's architect, to the extent such 
correction is necessary in order for Tenant to obtain a building permit or a certificate of 
occupancy for the Expansion Space Improvements in the Expansion Space for general office 
purposes; provided that nothing contained herein shall be deemed to prohibit Landlord from 
obtaining a variance or relying upon a grandfathered right in order to achieve compliance with 

Exhibit C-1 
-1- 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
those codes.  Notwithstanding the foregoing, Landlord shall have the right to contest any 
alleged violation in good faith, including, without limitation, the right to apply for and obtain 
a waiver or deferment of compliance, the right to assert any and all defenses allowed by law, 
and the right to appeal any decisions, judgments or rulings to the fullest extent permitted by 
law, and Landlord's obligation to perform work or take such other action to cure a violation 
under this Section shall apply after the exhaustion of any and all rights to appeal or contest. 

Section 2 

EXPANSION SPACE IMPROVEMENTS 

2.1 

Expansion Space Improvement Allowance.  Tenant shall be entitled to 
a one-time tenant improvement allowance (the "Expansion Space Improvement Allowance") 
in the amount of up to, but not exceeding $45.00 per rentable square foot of the Expansion 
Space (i.e., up to $2,249,145.00, based on 49,981 rentable square feet in the Expansion 
Space), for the costs relating to the initial design and construction of Tenant's improvements 
which are permanently affixed to the Expansion Space (the "Expansion Space 
Improvements").  In no event shall Landlord be obligated to make disbursements pursuant to 
this Tenant Work Letter in a total amount which exceeds the Expansion Space Improvement 
Allowance.  Tenant shall not be entitled to receive any cash payment or credit against Rent or 
otherwise for any unused portion of the Expansion Space Improvement Allowance which is 
not used to pay for the Expansion Space Improvement Allowance Items (as such term is 
defined below). In no event shall the Expansion Space Improvement Allowance be used for 
purposes of constructing improvements in the Expansion Space for purposes of offering space 
for sublease or for the benefit of a subtenant.  Notwithstanding anything to the contrary in this 
Section 2.1, so long as the Expansion Space  Improvements  have been completed  and all cost 
of the Expansion Space  Improvements  have been paid, and so long as no Event of Default 
exists  under the Lease, Tenant  may use up to $499,810.00 of any unused portion  of the 
Expansion Space Improvement Allowance for furniture, cabling and/or moving expenses. 

2.2 

Disbursement of the Expansion Space Improvement Allowance.  

Except as otherwise set forth in this Tenant Work Letter, the Expansion Space Improvement 
Allowance shall be disbursed by Landlord (each of which disbursement shall be made 
pursuant to Landlord's standard disbursement process), only for the following items and costs 
(collectively, the "Expansion Space Improvement Allowance Items"): 

2.2.1  Payment of the fees of the "Architect" and the "Engineers," as 

those terms are defined in Section 3.1 of this Tenant Work Letter, and payment of the fees 
incurred by, and the cost of documents and materials supplied by, Landlord and Landlord's 
consultants in connection with the preparation and review of the "Construction Drawings," as 
that term is defined in Section 3.1 of this Tenant Work Letter; 

construction of the Expansion Space Improvements; 

2.2.2  The payment of plan check, permit and license fees relating to 

Exhibit C-1 
-2- 

 
 
 
 
 
 
 
 
 
2.2.3  The cost of construction of the Expansion Space Improvements, 

including, without limitation, contractors' fees and general conditions, testing and inspection 
costs, costs of utilities, trash removal, parking and hoists; 

2.2.4  The cost of any changes in the Base, Shell and Core when such 
changes are required by the Construction Drawings (including if such changes are due to the 
fact that such work is prepared on an unoccupied basis), such cost to include all direct 
architectural and/or engineering fees and expenses incurred in connection therewith; 

Expansion Space Improvements required by any applicable laws;  

2.2.5  The cost of any changes to the Construction Drawings or 

2.2.6  Sales and use taxes and Title 24 fees; 

Section 4.3.2 of this Tenant Work Letter; 

2.2.7  "Landlord's Supervision Fee," as that term is defined in 

2.2.8  The costs and expenses associated with complying with all 

national, state and local codes, including California Energy Code, Title 24, including, without 
limitation, all costs associated with any lighting or HVAC retrofits required thereby; and 

the construction of the Expansion Space Improvements. 

2.2.9  All other costs to be expended by Landlord in connection with 

2.3 

Specifications for Building Standard Components.  Landlord has 

established specifications (the "Specifications") for the Building standard components to be 
used in the construction of the Expansion Space Improvements in the Expansion Space, which 
Specifications have been received by Tenant.  Unless otherwise agreed to by Landlord, the 
Expansion Space Improvements shall comply with the Specifications.  Landlord may make 
changes to the Specifications from time to time. 

Section 3 

CONSTRUCTION DRAWINGS 

3.1 

Selection of Architect/Construction Drawings.  Landlord shall retain an 
architect/space planner (the "Architect") to prepare the "Construction Drawings," as that term 
is defined in this Section 3.1.  Landlord shall retain Landlord's engineering consultants (the 
"Engineers") to prepare all plans and engineering working drawings relating to the structural, 
mechanical, electrical, plumbing, HVAC, lifesafety, and sprinkler work in the Expansion 
Space.  The plans and drawings to be prepared by Architect and the Engineers hereunder shall 
be known collectively as the "Construction Drawings."  Notwithstanding that any 
Construction Drawings are reviewed by Landlord or prepared by its Architect, Engineers and 
consultants, and notwithstanding any advice or assistance which may be rendered to Tenant 
by Landlord or Landlord's Architect, Engineers, and consultants, Landlord shall have no 
liability whatsoever in connection therewith and shall not be responsible for any omissions or 

Exhibit C-1 
-3- 

 
 
 
 
 
 
 
 
 
errors contained in the Construction Drawings, and Tenant's waiver and indemnity set forth in 
the Lease shall specifically apply to the Construction Drawings. 

3.2 

Final Space Plan.  No later than thirty (30) days after the date hereof, 

Tenant shall meet with Landlord's Architect and provide Landlord's Architect with 
information regarding the preliminary layout and designation of all proposed offices, rooms 
and other partitioning, and their intended use and equipment to be contained therein (the 
"Information").  Landlord and Architect shall, based on such Information (subject to changes 
reasonably required by Landlord), prepare the final space plan for Expansion Space 
Improvements in the Expansion Space (collectively, the "Final Space Plan"), which Final 
Space Plan shall include a layout and designation of all offices, rooms and other partitioning, 
their intended use, and equipment to be contained therein, and shall deliver the Final Space 
Plan to Tenant for Tenant's approval.  Tenant shall approve or reasonably disapprove the 
Final Space Plan or any revisions thereto within ten (10) business days after Landlord delivers 
the Final Space Plan or such revisions to Tenant; provided, however, that Tenant may only 
disapprove the Final Space Plan to the extent the same is not (subject to changes reasonably 
required by Landlord) in substantial conformance with the Information provided by Tenant to 
Architect ("Space Plan Design Problem").  Tenant's failure to disapprove the Final Space Plan 
for any Space Plan Design Problem or any revisions thereto by written notice to Landlord 
(which notice shall specify in detail the reasonable reasons for Tenant's disapproval pertaining 
to any Space Plan Design Problem) within said ten (10) business day period shall be deemed 
to constitute Tenant's approval of the Final Space Plan or such revisions. 

3.3 

Final Working Drawings.  Based on the Final Space Plan, Landlord 

shall cause the Architect and the Engineers to complete the architectural and engineering 
drawings for the Expansion Space, and Architect shall compile a fully coordinated set of 
architectural, structural, mechanical, electrical and plumbing working drawings in a form 
which is complete to allow subcontractors to bid on the work and to obtain all applicable 
permits (collectively, the "Final Working Drawings") and shall submit the same to Tenant for 
Tenant's approval.  The Final Working Drawings shall incorporate modifications to the Final 
Space Plan as necessary to comply with the floor load and other structural and system 
requirements of the Building.  To the extent that the finishes and specifications are not 
completely set forth in the Final Space Plan for any portion of the Expansion Space 
Improvements depicted thereon, the actual specifications and finish work shall be in 
accordance with the Specifications.  Tenant shall approve or reasonably disapprove the Final 
Working Drawings or any revisions thereto within ten (10) business days after Landlord 
delivers the Final Working Drawings or any revisions thereto to Tenant; provided, however, 
that Tenant may only disapprove the Final Working Drawings to the extent the same are not 
(subject to changes reasonably required by Landlord) in substantial conformance with the 
Final Space Plan ("Working Drawing Design Problem").  Tenant's failure to reasonably 
disapprove the Final Working Drawings or any revisions thereto by written notice to Landlord 
(which notice shall specify in detail the reasonable reasons for Tenant's disapproval pertaining 
to any Working Drawing Design Problem) within said ten (10) business day period shall be 
deemed to constitute Tenant's approval of the Final Working Drawings or such revisions. 

Exhibit C-1 
-4- 

 
 
 
 
 
 
 
 
3.4 

Approved Working Drawings.  The Final Working Drawings shall be 

approved or deemed approved by Tenant (the "Approved Working Drawings") prior to the 
commencement of the construction of the Expansion Space Improvements.  Landlord shall 
cause the Architect to submit the Approved Working Drawing to the applicable local 
governmental agency for all applicable building permits necessary to allow "Contractor," as 
that term is defined in Section 4.1 of this Tenant Work Letter, to commence and fully 
complete the construction of the Expansion Space Improvements (the "Permits").  No 
changes, modifications or alterations in the Approved Working Drawings may be made 
without the prior written consent of Landlord, not to be unreasonably withheld, conditioned or 
delayed beyond the applicable time periods in this Section 3, provided that Landlord may 
withhold its consent, in its sole discretion, to any change in the Approved Working Drawings, 
if such change would directly or indirectly delay the Substantial Completion of the Expansion 
Space. 

3.5 

Time Deadlines.  Tenant shall use reasonable efforts to cooperate with 
Architect, the Engineers, and Landlord to complete all phases of the Construction Drawings 
and the permitting process and to receive the Permits, and with Contractor, for approval of the 
"Cost Proposal," as that term is defined in Section 4.2 below as soon as possible after the 
execution of the Amendment and, in this regard, to the extent Landlord considers such 
meeting(s) to be reasonably necessary, Tenant shall meet with Landlord on a weekly basis to 
discuss Tenant's progress in connection with the same. 

3.6 

Design Problem.  Notwithstanding anything to the contrary in this 

Tenant Work Letter, Landlord shall be deemed to have acted reasonably in disapproving plans 
or designs if Landlord determines in good faith that the matter disapproved constitutes or 
would create a Design Problem (as defined below).  As used herein, a "Design Problem" shall 
mean (i) adverse effect on the structural integrity of the Building; (ii) possible damage to the 
Building's systems; (iii) non-compliance with applicable codes; (iv) adverse effect on the 
exterior appearance of the Building; (v) creation of the potential for unusual expenses to be 
incurred upon the removal of the alteration or improvement and the restoration of the 
Expansion Space upon termination of this Lease, unless Tenant agrees to pay for the 
incremental removal costs caused by the non-typical alterations; (vi) creation of the potential 
for unusual expenses to be incurred in connection with the maintenance by Landlord of the 
alteration or improvement, unless Tenant agrees to pay for the incremental maintenance costs 
caused by the non-typical alterations, (vii) a material effect any other tenant or occupant of 
the Building, (viii) creation of an obligation to make other alterations, additions or 
improvements to the Expansion Space or Common Areas in order to comply with applicable 
laws (including, without limitation, the Americans with Disabilities Act) or (ix) adverse effect 
on the LEED rating of the Building.  

Section 4 

CONSTRUCTION OF THE EXPANSION SPACE IMPROVEMENTS 

4.1 

Contractor.  A contractor, under the supervision of and selected by 

Landlord, shall construct the Expansion Space Improvements (the "Contractor"). 

Exhibit C-1 
-5- 

 
 
 
 
 
 
 
 
 
4.2 

Cost Proposal.  After the Approved Working Drawings are signed by 

Landlord and Tenant, Landlord cause the Contractor to competitively bid the subcontracts 
with the major trades to at least three (3) subcontractors in each such major trade and based on 
that bidding process shall provide Tenant with a cost proposal in accordance with the 
Approved Working Drawings, which cost proposal shall include, as nearly as possible, the 
cost of all Expansion Space Improvement Allowance Items to be incurred by Tenant in 
connection with the construction of the Expansion Space Improvements (the "Cost 
Proposal").  Notwithstanding the foregoing, portions of the cost of the Expansion Space 
Improvements may be delivered to Tenant as such portions of the Expansion Space 
Improvements are priced by Contractor (on an individual item-by-item or trade-by-trade 
basis), even before the Approved Working Drawings are completed (the "Partial Cost 
Proposal").  Tenant shall approve and deliver the Cost Proposal to Landlord within ten (10) 
business days of the receipt of the same (or, as to a Partial Cost Proposal, within five (5) 
business days of receipt of the same).  The date by which Tenant must approve and deliver the 
Cost Proposal, or the last Partial Cost Proposal to Landlord, as the case may be, shall be 
known hereafter as the "Cost Proposal Delivery Date."  The total of all Partial Cost Proposals, 
if any, shall be known as the Cost Proposal.   

4.3 

Construction of Expansion Space Improvements by Landlord's 

Contractor under the Supervision of Landlord. 

4.3.1.  Over-Allowance Amount.  On the Cost Proposal Delivery Date, 
Tenant shall deliver to Landlord cash in an amount (the "Over-Allowance Amount") equal to 
the difference between (i) the amount of the Cost Proposal and (ii) the amount of the 
Expansion Space Improvement Allowance (less any portion thereof already disbursed by 
Landlord, or in the process of being disbursed by Landlord, on or before the Cost Proposal 
Delivery Date).  The Over-Allowance Amount shall be disbursed by Landlord prior to the 
disbursement of any then remaining portion of the Expansion Space Improvement Allowance, 
and such disbursement shall be pursuant to the same procedure as the Expansion Space 
Improvement Allowance.  In the event that, after the Cost Proposal Delivery Date, any 
revisions, changes, or substitutions shall be made to the Construction Drawings or the 
Expansion Space Improvements, any additional costs which arise in connection with such 
revisions, changes or substitutions shall be added to the Cost Proposal and shall be paid by 
Tenant to Landlord immediately upon Landlord's request to the extent such additional costs 
increase any existing Over-Allowance Amount or result in an Over-Allowance Amount.  
Following completion of the Expansion Space Improvements, Landlord shall deliver to 
Tenant a final cost statement which shall indicate the final costs of the Expansion Space 
Improvement Allowance Items, and if such cost statement indicates that Tenant has underpaid 
or overpaid the Over-Allowance Amount, then within ten (10) business days after receipt of 
such statement, Tenant shall deliver to Landlord the amount of such underpayment or 
Landlord shall return to Tenant the amount of such overpayment, as the case may be. 

4.3.2  Landlord Supervision.  After Landlord selects the Contractor, 

Landlord shall independently retain Contractor to construct the Expansion Space 
Improvements in accordance with the Approved Working Drawings and the Cost Proposal 
and Landlord shall supervise the construction by Contractor, and Tenant shall pay a 

Exhibit C-1 
-6- 

 
 
 
 
 
 
 
 
construction supervision and management fee (the "Landlord's Supervision Fee") to Landlord 
in an amount equal to the product of (i) three percent (3%) and (ii) an amount equal to the 
Expansion Space Improvement Allowance plus the Over-Allowance Amount (as such Over-
Allowance Amount may increase pursuant to the terms of this Tenant Work Letter). 

4.3.3  Contractor's Warranties and Guaranties.  Landlord hereby 

assigns to Tenant all warranties and guaranties by Contractor relating to the Expansion Space 
Improvements, which assignment shall be on a non-exclusive basis such that the warranties 
and guarantees may be enforced by Landlord and/or Tenant, and Tenant hereby waives all 
claims against Landlord relating to, or arising out of the construction of, the Expansion Space 
Improvements. 

Section 5 

SUBSTANTIAL COMPLETION; 

EXPANSION SPACE COMMENCEMENT DATE 

5.1 

Substantial Completion.  For purposes of the Amendment, including 

for purposes of determining the Expansion Space Commencement Date "Substantial 
Completion" of the Expansion Space shall occur upon the later of (a) completion of 
construction of the Expansion Space Improvements in the Expansion Space pursuant to the 
Approved Working Drawings, with the exception of any punchlist items and any tenant 
fixtures, work-stations, built-in furniture, or equipment to be installed by Tenant or under the 
supervision of Contractor, and (b) Landlord's receipt of a final sign-off on the permits for the 
Expansion Space Improvements sufficient under customary practices in Redwood City, 
California, to allow legal occupancy of the Expansion Space. 

5.2 

Tenant Delays.  If there shall be a delay or there are delays in the 

Substantial Completion of the Expansion Space (as a direct, indirect, partial, or total result of 
any of the following (collectively, "Tenant Delays"): 

5.2.1  Tenant's failure to timely approve any matter requiring Tenant's 

approval, including a Partial Cost Proposal or the Cost Proposal and/or Tenant's failure to 
timely perform any other obligation or act required of Tenant hereunder; 

the Lease; 

5.2.2  a breach by Tenant of the terms of this Tenant Work Letter or 

5.2.3  Tenant's request for changes in the Construction Drawings; 

5.2.4  Tenant's requirement for materials, components, finishes or 

improvements which are not available in a reasonable time (based upon the anticipated date of 
the Expansion Space Commencement Date) or which are different from, or not included in, 
the Specifications; 

Exhibit C-1 
-7- 

 
 
 
 
 
 
 
 
 
 
Working Drawings; 

5.2.5  changes to the Base, Shell and Core required by the Approved 

5.2.6  any changes in the Construction Drawings and/or the Expansion 

Space Improvements required by (i) applicable laws if such changes are directly attributable 
to Tenant's use of the Expansion Space or Tenant's specialized Expansion Space 
Improvement(s) (as reasonably determined by Landlord), and/or (ii) Landlord pursuant to 
Section 4.2 above; or 

employees; 

5.2.7  any other acts or omissions of Tenant, or its agents, or 

5.2.8 

then, notwithstanding anything to the contrary set forth in the 

Amendment and regardless of the actual date of the Substantial Completion of the Expansion 
Space, the Expansion Space Commencement Date shall be deemed to be the date the 
Expansion Space Commencement Date would have occurred if no Tenant Delays, as set forth 
above, had occurred. 

Section 6 

MISCELLANEOUS 

6.1 

Tenant's Representative.  Tenant has designated Rich Carter as its sole 
representative with respect to the matters set forth in this Tenant Work Letter, who shall have 
full authority and responsibility to act on behalf of the Tenant as required in this Tenant Work 
Letter. 

6.2 

Landlord's Representative.  Landlord has designated Christine Scheerer 
as its sole representative with respect to the matters set forth in this Tenant Work Letter, who, 
until further notice to Tenant, shall have full authority and responsibility to act on behalf of 
the Landlord as required in this Tenant Work Letter. 

6.3 

Time of the Essence in This Tenant Work Letter.  Unless otherwise 

indicated, all references herein to a "number of days" shall mean and refer to calendar days.  
In all instances where Tenant is required to approve or deliver an item, if no written notice of 
approval is given or the item is not delivered within the stated time period, at Landlord's sole 
option, at the end of said period the item shall automatically be deemed approved or delivered 
by Tenant and the next succeeding time period shall commence. 

6.4 

Tenant's Lease Default.  Notwithstanding any provision to the contrary 
contained in the Lease, if an Event of Default by Tenant under the Lease has occurred at any 
time on or before the Substantial Completion of the Expansion Space and is continuing, then 
(i) in addition to all other rights and remedies granted to Landlord pursuant to the Lease, at 
law and/or in equity, Landlord shall have the right to withhold payment of all or any portion 
of the Expansion Space Improvement Allowance and/or Landlord may cause Contractor to 
cease the construction of the Expansion Space (in which case, Tenant shall be responsible for 

Exhibit C-1 
-8- 

 
 
 
 
 
 
 
 
 
any delay in the Substantial Completion of the Expansion Space caused by such work 
stoppage as set forth in Section 5.2 of this Tenant Work Letter), and (ii) all other obligations 
of Landlord under the terms of this Tenant Work Letter shall be forgiven until such time as 
such Event of Default is cured pursuant to the terms of the Lease (in which case, Tenant shall 
be responsible for any delay in the Substantial Completion of the Expansion Space caused by 
such inaction by Landlord).  In addition, if the Lease is terminated prior to the Expansion 
Space Commencement Date, for any reason due to an Event of Default by Tenant under the 
Lease, in addition to any other remedies available to Landlord under the Lease, at law and/or 
in equity, Tenant shall pay to Landlord, as Additional Rent under the Lease, within ten (10) 
days of receipt of a statement therefor, any and all reasonable out of pocket costs (if any) 
incurred by Landlord (including any portion of the Expansion Space Improvement Allowance 
disbursed by Landlord) and not reimbursed or otherwise paid by Tenant through the date of 
such termination in connection with the Expansion Space Improvements to the extent 
planned, installed and/or constructed as of such date of termination, including, but not limited 
to, any costs related to the removal of all or any portion of the Expansion Space 
Improvements and restoration costs related thereto. 

6.5 

Access. Upon reasonable prior notice, Landlord shall arrange for 

Tenant and Tenant's agents to have access to inspect the Expansion Space, which inspection 
shall take place at a time reasonably acceptable to Landlord, Tenant and the existing tenant.  
Tenant and Tenant's agents shall be accompanied by Landlord and/or existing tenant and/or 
their respective agents, to the extent Landlord and/or existing tenant so elect.

Exhibit C-1 
-9- 

 
 
 
 
 
 
 
 
EXHIBIT D 

BUILDING-TOP SIGNAGE 

(See Attached.) 

Exhibit D 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Subsidiary 

Nevro Medical Sarl 
Nevro Medical Limited 
Nevro Medical Pty Ltd. 
Nevro Germany GmbH 

List of Subsidiaries of 
Nevro Corp.

  Jurisdiction of Incorporation or Organization 

  Switzerland 
  United Kingdom 
  Australia 
  Germany 

Exhibit 21.1 

 
 
 
 
 
 
  
 
  
Exhibit 23.1 

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM  

We hereby consent to the incorporation by reference in the Registration Statements on Form S-3 (No. 
333-211864) and Form S-8 (Nos. 333-209816, 333-202857, and 333-200145) of Nevro Corp. of our report 
dated February 23, 2017 relating to the consolidated financial statements and the effectiveness of internal 
control over financial reporting, which appears in this Form 10-K.  

/s/ PricewaterhouseCoopers LLP 

San Jose, California 
February 23, 2017 

 
CERTIFICATION OF THE CHIEF EXECUTIVE OFFICER 
PURSUANT TO 
SECURITIES EXCHANGE ACT RULES 13A-14(A) AND 15D-14(A) 

Exhibit 31.1 

I, Rami Elghandour, certify that: 

1. 

2. 

3. 

4. 

I have reviewed this Annual Report on Form 10-K of Nevro Corp.; 

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a 
material  fact  necessary  to  make  the  statements  made,  in  light  of  the  circumstances  under  which  such 
statements were made, not misleading with respect to the period covered by this report; 

Based  on  my  knowledge,  the  financial  statements,  and  other  financial  information  included  in  this  report, 
fairly  present  in  all  material  respects  the  financial  condition,  results  of  operations  and  cash  flows  of  the 
registrant as of, and for, the periods presented in this report; 

The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure 
controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over 
financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have: 

(a)  Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to 
be designed under our supervision, to ensure that material information relating to the registrant, 
including its consolidated subsidiaries, is made known to us by others within those entities, particularly 
during the period in which this report is being prepared; 

(b)  Designed such internal control over financial reporting, or caused such internal control over financial 

reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability 
of financial reporting and the preparation of financial statements for external purposes in accordance 
with generally accepted accounting principles; 

(c)  Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this 

report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of 
the period covered by this report based on such evaluation; and 

(d)  Disclosed in this report any change in the registrant’s internal control over financial reporting that 

occurred during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the 
case of an annual report) that has materially affected, or is reasonably likely to materially affect, the 
registrant’s internal control over financial reporting; and 

5. 

The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal 
control over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of 
directors (or persons performing the equivalent functions): 

(a)  All significant deficiencies and material weaknesses in the design or operation of internal control over 

financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, 
process, summarize and report financial information; and 

(b)  Any fraud, whether or not material, that involves management or other employees who have a 

significant role in the registrant’s internal control over financial reporting. 

Date: February 23, 2017 

/s/ Rami Elghandour 
Rami Elghandour 
Chief Executive Officer 
(Principal Executive Officer) 

 
 
 
CERTIFICATION OF THE CHIEF FINANCIAL OFFICER 
PURSUANT TO 
SECURITIES EXCHANGE ACT RULES 13A-14(A) AND 15D-14(A) 

Exhibit 31.2 

I, Andrew H. Galligan, certify that: 

1. 

2. 

3. 

4. 

I have reviewed this Annual Report on Form 10-K of Nevro Corp.; 

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a 
material fact necessary to make the statements made, in light of the circumstances under which such 
statements were made, not misleading with respect to the period covered by this report; 

Based on my knowledge, the financial statements, and other financial information included in this report, 
fairly present in all material respects the financial condition, results of operations and cash flows of the 
registrant as of, and for, the periods presented in this report; 

The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure 
controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over 
financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have: 

(a)  Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to 
be designed under our supervision, to ensure that material information relating to the registrant, 
including its consolidated subsidiaries, is made known to us by others within those entities, particularly 
during the period in which this report is being prepared; 

(b)  Designed such internal control over financial reporting, or caused such internal control over financial 

reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability 
of financial reporting and the preparation of financial statements for external purposes in accordance 
with generally accepted accounting principles; 

(c)  Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this 

report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of 
the period covered by this report based on such evaluation; and 

(d)  Disclosed in this report any change in the registrant’s internal control over financial reporting that 

occurred during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the 
case of an annual report) that has materially affected, or is reasonably likely to materially affect, the 
registrant’s internal control over financial reporting; and 

5. 

The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal 
control over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of 
directors (or persons performing the equivalent functions): 

(a)  All significant deficiencies and material weaknesses in the design or operation of internal control over 

financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, 
process, summarize and report financial information; and 

(b)  Any fraud, whether or not material, that involves management or other employees who have a 

significant role in the registrant’s internal control over financial reporting. 

Date: February 23, 2017 

/s/ Andrew H. Galligan  
Andrew H. Galligan 
Chief Financial Officer 
(Principal Financial and Accounting Officer) 

 
 
 
CERTIFICATION PURSUANT TO 
18 U.S.C. SECTION 1350, 
AS ADOPTED PURSUANT TO 
SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002 

Exhibit 32.1 

In connection with the Annual Report of Nevro Corp. (the “Company”) on Form 10-K for the fiscal year ended 
December 31, 2016, as filed with the Securities and Exchange Commission (the “Report”), Rami Elghandour, Chief 
Executive Officer of the Company, and Andrew H. Galligan, Chief Financial Officer of the Company, respectively, 
do each hereby certify, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-
Oxley Act of 2002, that: 

 

 

The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange 
Act of 1934; and 

The information in the Report fairly presents, in all material respects, the financial condition and results 
of operations of the Company. 

Date: February 23, 2017 

/s/ Rami Elghandour  
Rami Elghandour 
Chief Executive Officer 
(principal executive officer) 

/s/ Andrew H. Galligan  
Andrew H. Galligan 
Chief Financial Officer 
(principal financial and accounting officer)