SEC Comment Letter for NCR Voyix Corp (VYX, NCRRP) (CIK 0000070866) (VYX) — Dec 7, 2015
NCR Voyix Corp (VYX, NCRRP) (CIK 0000070866)
Date: Dec. 7, 2015 · CIK: 0000070866 · Accession: 0000000000-15-056625
AI Filing Summary & Sentiment
Letter
Mail Stop 4561 December 4, 2015 Robert P. Fishman Senior Vice President and Chief Financial Officer NCR Corporation 3097 Satellite Boulevard Duluth, GA 30096
Re: NCR Corporation Form 10 -K for the Fiscal Year Ended December 31, 2014 Filed February 27, 2015 File No. 001 -00395
Dear Mr. Fishman :
We have reviewed your November 18, 2015 response to our comment letter 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 co mments. Unless we note otherwise, our references to prior c omments are to comments in our November 4, 2015 letter.
Form 10 -K for the Fiscal Year Ended December 31, 2014
Management’s Discussion and Analysis of Financial Condition and Results o f Operations
2014 Overview, page 21
1. We note your response to prior comment 3. You state here that the growth in software - related revenue is a significant theme in 2014 and in your Forms 10 -Q filed in 2015 , you state that a key initiative is to migrate your revenu e to higher margin software and recurring services revenue. Given the emphasis placed on this strategy , it would appear that quantifying the amount of software -related revenue or the percentage of such revenue to total revenue , would add context to this discussion and cons istency with the
Robert P. Fishman NCR Corporation December 4, 2015 Page 2
information provided in your earnings releases on Forms 8 -K and your earnings calls. Please tell us your consideration for incorporating total software -related revenue for each period presented, or comparable measure s, into this discussio n in future filings. We refer you to Item 303(a) of Regulation S -K and Section III of SEC Release 33 -8350.
You may contact Frank Knapp, Staff Accountant, at (202) 551 -3805, or Melissa Kindelan, at (202) 551 -3564, if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3499 with any other questions.
Sincerely,
/s/ Kathleen Collins
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Mail Stop 4561 December 4, 2015 Robert P. Fishman Senior Vice President and Chief Financial Officer NCR Corporation 3097 Satellite Boulevard Duluth, GA 30096 Re: NCR Corporation Form 10 -K for the Fiscal Year Ended December 31, 2014 Filed February 27, 2015 File No. 001 -00395 Dear Mr. Fishman : We have reviewed your November 18, 2015 response to our comment letter 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 co mments. Unless we note otherwise, our references to prior c omments are to comments in our November 4, 2015 letter. Form 10 -K for the Fiscal Year Ended December 31, 2014 Management’s Discussion and Analysis of Financial Condition and Results o f Operations 2014 Overview, page 21 1. We note your response to prior comment 3. You state here that the growth in software - related revenue is a significant theme in 2014 and in your Forms 10 -Q filed in 2015 , you state that a key initiative is to migrate your revenu e to higher margin software and recurring services revenue. Given the emphasis placed on this strategy , it would appear that quantifying the amount of software -related revenue or the percentage of such revenue to total revenue , would add context to this discussion and cons istency with the Robert P. Fishman NCR Corporation December 4, 2015 Page 2 information provided in your earnings releases on Forms 8 -K and your earnings calls. Please tell us your consideration for incorporating total software -related revenue for each period presented, or comparable measure s, into this discussio n in future filings. We refer you to Item 303(a) of Regulation S -K and Section III of SEC Release 33 -8350. You may contact Frank Knapp, Staff Accountant, at (202) 551 -3805, or Melissa Kindelan, at (202) 551 -3564, if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3499 with any other questions. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services