TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo January 28, 2021 Daniel Barton Chief Executive Officer Forian Inc. 41 University Drive, Suite 400 Newtown, Pennsylvania 18940 Re: Forian Inc. Amendment No. 2 to Registration Statement on Form S-4 Filed January 19, 2021 File No. 333-250938 Dear Mr. Barton: We have reviewed your amended registration statement and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 2 to Form S-4 filed January 19, 2021 Helix Financial Statements Revenue Recognition, page F-17 1. Please tell us why you recognize revenues from installation and training under private sector contracts upon completion of training. Also tell us, and disclose, how you identify and allocate revenues to performance obligations in your private sector contracts in accordance with ASC 606-10-25 and ASC 606-10-32. Please address performance obligations for the following, as applicable: term licenses, installation, training, Daniel Barton Forian Inc. January 28, 2021 Page 2 post installation customer support, software license renewals, and service contract renewals. You may contact Joseph M. Kempf, Senior Staff Accountant, at (202) 551-3352 or Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions. Sincerely, FirstName LastNameDaniel Barton Division of Corporation Finance Comapany NameForian Inc. Office of Technology January 28, 2021 Page 2 cc: Darrick Mix, Esq. FirstName LastName