TEXT-EXTRACT 2 filename2.txt November 21, 2019 Joshua Ballard Chief Financial Officer Energy Recovery, Inc. 1717 Doolittle Drive San Leandro, CA 94577 Re: Energy Recovery, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed on March 7, 2019 File No. 001-34112 Dear Mr. Ballard: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2018 Consolidated Finanical Statements Notes to Consolidated Financial Statements Note 3 - Revenues License and Development Revenue Recognition - Oil & Gas Segment, page 77 1. Please clarify how you determined it is appropriate to use the cost to cost method to recognize revenue and how you have the ability to reasonably measure your progress toward full commercial launch. As part of your response, tell us how you considered ASC 606-10-25-37. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Joshua Ballard Energy Recovery, Inc. November 21, 2019 Page 2 You may contact Laura Veator, Staff Accountant, at 202-551-3716 or Stephen Krikorian, Accounting Branch Chief, at 202-551-3488 with any questions. FirstName LastNameJoshua Ballard Sincerely, Comapany NameEnergy Recovery, Inc. Division of Corporation Finance November 21, 2019 Page 2 Office of Technology FirstName LastName