SEC Comment Letter for L3HARRIS TECHNOLOGIES, (LHX) — Sep 10, 2014
L3HARRIS TECHNOLOGIES, INC. /DE/
Date: Sept. 10, 2014 · CIK: 0000202058 · Accession: 0000000000-14-045344
AI Filing Summary & Sentiment
File numbers found in text: 001-03863
Letter
September 10 , 2014 Via E-Mail Mr. Miguel A. Lopez Chief Financial Officer Harris Corporation 1025 West NASA Boulevard Melbourne, FL 32919
Re: Harris Corporation Form 10-K for the year ended June 27, 2014 Filed August 25 , 2014 File No. 001-03863
Dear Mr. Lopez :
We have reviewed your filing and have the following comments . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten 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 circumst ances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the fiscal year ended June 27, 2014 Management’s Discussion and Analysis, page 30 Operations Review, page 34
1. We note from your disclosure on page 35 you recognized an out -of-period adjustment in the third quarter of fiscal 2014 related to your post -employment benefit plan that reduced general and a dministrative expenses. Further, we note from your Integrated Network Solution Segment discussion on page 38 that an out -of-period adjustment was also made to revenue and cost of sales for satellite and terrestrial communications services. In this regard, please explain to us in detail the n ature, facts and circumstances surrounding each of the out -of-period adjustments , including the amou nt(s) involved and the period(s) to which the adjustment (s) relate. Please explain why recognition of the out -of-period adjustments during the third quarte r of fiscal 2014 was appropriate. We may have further comment upon receipt of your response.
Mr. Miguel A. Lopez Harris Corporation September 10 , 2014 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require . Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures th ey have made.
In connection with responding to our comments, please p rovide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person u nder the federal securities laws of the United States.
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, Jean Yu at (202) 551-3305 if you have questions regarding comments on the financial statements and related matters. You may also co ntact me at (202) 551 -3813 .
Sincerely,
/s/ Linda Cvrkel
Show Raw Text
September 10 , 2014 Via E-Mail Mr. Miguel A. Lopez Chief Financial Officer Harris Corporation 1025 West NASA Boulevard Melbourne, FL 32919 Re: Harris Corporation Form 10-K for the year ended June 27, 2014 Filed August 25 , 2014 File No. 001-03863 Dear Mr. Lopez : We have reviewed your filing and have the following comments . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten 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 circumst ances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10 -K for the fiscal year ended June 27, 2014 Management’s Discussion and Analysis, page 30 Operations Review, page 34 1. We note from your disclosure on page 35 you recognized an out -of-period adjustment in the third quarter of fiscal 2014 related to your post -employment benefit plan that reduced general and a dministrative expenses. Further, we note from your Integrated Network Solution Segment discussion on page 38 that an out -of-period adjustment was also made to revenue and cost of sales for satellite and terrestrial communications services. In this regard, please explain to us in detail the n ature, facts and circumstances surrounding each of the out -of-period adjustments , including the amou nt(s) involved and the period(s) to which the adjustment (s) relate. Please explain why recognition of the out -of-period adjustments during the third quarte r of fiscal 2014 was appropriate. We may have further comment upon receipt of your response. Mr. Miguel A. Lopez Harris Corporation September 10 , 2014 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require . Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures th ey have made. In connection with responding to our comments, please p rovide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person u nder the federal securities laws of the United States. You may contact Effie Simpson at (202) 551 -3346 , or in her absence, Jean Yu at (202) 551-3305 if you have questions regarding comments on the financial statements and related matters. You may also co ntact me at (202) 551 -3813 . Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief