SEC Comment Letter for INTEL CORP (INTC) (CIK 0000050863) (INTC) — May 7, 2012
INTEL CORP (INTC) (CIK 0000050863)
Date: May 7, 2012 · CIK: 0000050863 · Accession: 0000000000-12-023572
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-06217
Letter
May 7, 2012 Via Email Mr. Stacy J. Smith Senior Vice President and Chief Financial Officer Intel Corporation 2200 Mission College Boulevard Santa Clara, California 95054 Re: Intel Corporation Form 10-K for the Year Ended December 31, 2011 Filed February 23, 2012 File No. 000-06217
Dear Mr. Smith: We have reviewed your response dated Apr il 18, 2012 and have the following comments. In some of our comments, we may ask you to pr ovide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances please tell us w hy in your response. After reviewing the information you provide in response to these comments, we may have additional comments.
Management’s Discussion and Analysis . . ., page 23
Results of Operations, page 29
1. We note your response to prior comment 5. Please further discuss how you considered the microprocessor functionality delineations discussed on pages 3 and 13 in determining that all of your platforms c onstitute a single class of pr oducts under Regulation S-K Item 101(c)(1)(i).
Mr. Stacy J. Smith Intel Corporation May 7, 2012 Page 2
You may contact Julie Sherman at (202) 551-3640 or Jay Webb at (202) 551-3603 if you have questions regarding comments on the financ ial statements and related matters. Please contact Geoff Kruczek at (202) 551-3641 or me at (202) 551-3800 with any other questions.
Sincerely,
/s/ Amanda Ravitz
Amanda Ravitz Assistant Director
cc (by Email): Ronald Mueller—Gibson Dunn & Crutcher
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May 7, 2012 Via Email Mr. Stacy J. Smith Senior Vice President and Chief Financial Officer Intel Corporation 2200 Mission College Boulevard Santa Clara, California 95054 Re: Intel Corporation Form 10-K for the Year Ended December 31, 2011 Filed February 23, 2012 File No. 000-06217 Dear Mr. Smith: We have reviewed your response dated Apr il 18, 2012 and have the following comments. In some of our comments, we may ask you to pr ovide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances please tell us w hy in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Management’s Discussion and Analysis . . ., page 23 Results of Operations, page 29 1. We note your response to prior comment 5. Please further discuss how you considered the microprocessor functionality delineations discussed on pages 3 and 13 in determining that all of your platforms c onstitute a single class of pr oducts under Regulation S-K Item 101(c)(1)(i). Mr. Stacy J. Smith Intel Corporation May 7, 2012 Page 2 You may contact Julie Sherman at (202) 551-3640 or Jay Webb at (202) 551-3603 if you have questions regarding comments on the financ ial statements and related matters. Please contact Geoff Kruczek at (202) 551-3641 or me at (202) 551-3800 with any other questions. Sincerely, /s/ Amanda Ravitz Amanda Ravitz Assistant Director cc (by Email): Ronald Mueller—Gibson Dunn & Crutcher