AXONAxon Enterprise

We note your backlog increased substantially during 2016. Please clarify how backlog is calculated, disclose the amount of backlog attributable to each reportable segment, and disclose the amount of total backlog expected to be realized in the next year as required by Items 101(c)(1) and 101(c)(1)(viii) of Regulation S-K.

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To allow better insight into the changes in your backlog from period to period, please consider providing a roll-forward of backlog. The roll-forward should include current period beginning and ending balances, current period additions, cancellations and amounts recognized in sales, as well as any other major categories relevant to your facts and circumstances. Please also revise MD&A to address anticipated trends in margins based on the current backlog.

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Please separately present sales and cost of sales for products and services on the face of your statements of operations pursuant to Rules 5-03(b)(1) and (2) of Regulation S-X.

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For the current period, please reconcile the amounts reflected as changes in accounts and notes receivable and prepaid expenses and other assets presented in your statement of cash flows with changes in the related account balances in your balance sheets. This comment is also applicable to the March 31, 2017 Form 10-Q.

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We note you introduced TASER 60 in 2016, which allows customers to pay for hardware over an extended contractual life, typically five years. Please disclose the amount of revenue related to this program that you recognized during the periods presented.

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In addition, please explain how the extended payment terms under this program impact your ability to estimate the provision for doubtful accounts, your determination that collectability is reasonably assured, and your liquidity.

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Please disclose the amount of goodwill allocated to each reportable segment as of each balance sheet date as required by ASC 350-20-50-1.

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We note you introduced new subscription programs in 2017. Please clarify your revenue recognition policy related to this program.

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During your 1Q17 earnings call, you discussed the impact of a national free trial program, including your expectation that it could reduce margins and cost $5 million in the second half of the year. Please expand MD&A to disclose and discuss all known material trends, events or uncertainties that have had or are reasonably expected to have a material impact on your financial condition and results of operations.

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Refer to Item 303(a)(3) of Regulation S-K and SEC Release No. 33-8350.

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