SEC Comment Letter for L3HARRIS TECHNOLOGIES, (LHX) — Jan 21, 2020
L3HARRIS TECHNOLOGIES, INC. /DE/
Date: Jan. 21, 2020 · CIK: 0000202058 · Accession: 0000000000-20-000514
AI Filing Summary & Sentiment
File numbers found in text: 001-03863
Letter
January 21, 2020 Jesus Malave, Jr. Chief Financial Officer L3HARRIS TECHNOLOGIES, INC. 1025 West NASA Boulevard Melbourne, Florida 32919 Re:L3HARRIS TECHNOLOGIES, INC. Form 10-K for the Fiscal Year ended June 28, 2019 Form 8-K furnished October 30, 2019 File No. 001-03863 Dear Mr. Malave, Jr.: We have limited our review of your filing to the financial statements and related disclosures 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 8-K furnished October 30, 2019 Exhibit 99.1, page 1 1.We note your presentation of “combined” results and your disclosure that such information is not prepared in accordance with Article 11 of Regulation S-X. In this regard, it is unclear why you believe that the supplemental unaudited combined financial information is meaningful to an investor, considering that it excludes pro forma adjustments calculated under Article 11 of Regulation S-X. It also appears the presentation could be confusing to an investor. In this regard, please tell us how the supplemental unaudited combined financial information compares to amounts calculated in accordance with Article 11 of Regulation S-X. 2.We note your disclosure that the supplemental unaudited combined financial information does not give effect to the L3Harris merger under the acquisition method of accounting in accordance with ASC 805. Considering that the information does not give effect to ASC 805, it appears that the resulting non GAAP measures substitute individually tailored
FirstName LastNameJesus Malave, Jr. Comapany NameL3HARRIS TECHNOLOGIES, INC. January 21, 2020 Page 2 FirstName LastName Jesus Malave, Jr. L3HARRIS TECHNOLOGIES, INC. January 21, 2020 Page 2 measurement methods for those of GAAP and could violate Rule 100(b) of Regulation G. Please tell us how you considered Question 100.04 of the SEC Staff's Compliance & Disclosure Interpretations last updated April 4, 2018. In closing, 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. You may contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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January 21, 2020
Jesus Malave, Jr.
Chief Financial Officer
L3HARRIS TECHNOLOGIES, INC.
1025 West NASA Boulevard
Melbourne, Florida 32919
Re:L3HARRIS TECHNOLOGIES, INC.
Form 10-K for the Fiscal Year ended June 28, 2019
Form 8-K furnished October 30, 2019
File No. 001-03863
Dear Mr. Malave, Jr.:
We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 8-K furnished October 30, 2019
Exhibit 99.1, page 1
1.We note your presentation of “combined” results and your disclosure that such
information is not prepared in accordance with Article 11 of Regulation S-X. In this
regard, it is unclear why you believe that the supplemental unaudited combined financial
information is meaningful to an investor, considering that it excludes pro forma
adjustments calculated under Article 11 of Regulation S-X. It also appears the
presentation could be confusing to an investor. In this regard, please tell us how the
supplemental unaudited combined financial information compares to amounts calculated
in accordance with Article 11 of Regulation S-X.
2.We note your disclosure that the supplemental unaudited combined financial information
does not give effect to the L3Harris merger under the acquisition method of accounting in
accordance with ASC 805. Considering that the information does not give effect to ASC
805, it appears that the resulting non GAAP measures substitute individually tailored
FirstName LastNameJesus Malave, Jr.
Comapany NameL3HARRIS TECHNOLOGIES, INC.
January 21, 2020 Page 2
FirstName LastName
Jesus Malave, Jr.
L3HARRIS TECHNOLOGIES, INC.
January 21, 2020
Page 2
measurement methods for those of GAAP and could violate Rule 100(b) of Regulation G.
Please tell us how you considered Question 100.04 of the SEC Staff's Compliance
& Disclosure Interpretations last updated April 4, 2018.
In closing, 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.
You may contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing