SEC Comment Letter for NEC CORP (CIK 0000072127) — Jun 19, 2020
NEC CORP (CIK 0000072127)
Date: June 19, 2020 · CIK: 0000072127 · Accession: 0000000000-20-005489
AI Filing Summary & Sentiment
File numbers found in text: 000-12713
Referenced dates: May 28, 2020
Letter
United States securities and exchange commission logo June 19, 2020 Tetsuo Mukunoki Legal Counsel NEC Corporation 7-1, Shiba 5-chome Minato-ku, Tokyo 108-8001 Japan Re:NEC Corporation Amendment No. 1 to Registration Statement on Form 20-F Filed June 9, 2020 File No. 000-12713 Dear Mr. Mukunoki: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Unless otherwise noted, where prior comments are referred to they refer to our letter dated May 28, 2020. 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 and any amendment you may file in response to this comment, we may have additional comments. Amendment No. 1 to Registration Statement on Form 20-F Recent Developments Coronavirus, page 47 1.We note your response to prior comment 2. Please include your reasonably known anticipated effects of COVID-19 on your results of operations and financial condition beyond March 31, 2020. For further guidance, see Item 5.D of Form 20FR. 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.
FirstName LastNameTetsuo Mukunoki Comapany NameNEC Corporation June 19, 2020 Page 2 FirstName LastName Tetsuo Mukunoki NEC Corporation June 19, 2020 Page 2 You may contact Frank Knapp, Staff Accountant, at (202) 551-3805 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Michael C. Foland, Attorney-Advisor, at (202) 551-6711 or Larry Spirgel, Assistant Director, at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Michael Young
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United States securities and exchange commission logo
June 19, 2020
Tetsuo Mukunoki
Legal Counsel
NEC Corporation
7-1, Shiba 5-chome
Minato-ku, Tokyo 108-8001
Japan
Re:NEC Corporation
Amendment No. 1 to
Registration Statement on Form 20-F
Filed June 9, 2020
File No. 000-12713
Dear Mr. Mukunoki:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure. Unless
otherwise noted, where prior comments are referred to they refer to our letter dated May 28,
2020.
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 and any amendment you may file in response to
this comment, we may have additional comments.
Amendment No. 1 to Registration Statement on Form 20-F
Recent Developments
Coronavirus, page 47
1.We note your response to prior comment 2. Please include your reasonably known
anticipated effects of COVID-19 on your results of operations and financial condition
beyond March 31, 2020. For further guidance, see Item 5.D of Form 20FR.
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.
FirstName LastNameTetsuo Mukunoki
Comapany NameNEC Corporation
June 19, 2020 Page 2
FirstName LastName
Tetsuo Mukunoki
NEC Corporation
June 19, 2020
Page 2
You may contact Frank Knapp, Staff Accountant, at (202) 551-3805 or Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the
financial statements and related matters. Please contact Michael C. Foland, Attorney-Advisor, at
(202) 551-6711 or Larry Spirgel, Assistant Director, at (202) 551-3815 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Michael Young