SEC Comment Letter for SONY CORP (SONY, SNEJF) (CIK 0000313838) (SONY) — Jan 15, 2020
SONY CORP (SONY, SNEJF) (CIK 0000313838)
Date: Jan. 15, 2020 · CIK: 0000313838 · Accession: 0000000000-20-000360
AI Filing Summary & Sentiment
File numbers found in text: 001-06439
Letter
January 15, 2020 Hiroki Totoki Chief Financial Officer SONY CORP 7-1, Konan 1-Chome, Minato-Ku Tokyo 108-0075, Japan Re:SONY CORP Form 20-F for Fiscal Year Ended March 31, 2019 File No. 001-06439 Dear Mr. Totoki: 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 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 20-F for Fiscal Year Ended March 31, 2019 Financial Statements Summary of Significant Accounting Policies Revenue Recognition, page F-20 1.We note your disclosure that revenues in the HE&S, IP&S, MC and Semiconductors segments are recognized when (or as) performance obligations are satisfied. Please address the following and revise your disclosures as appropriate: •Clarify the nature of the performance obligations in your contracts. Reference ASC 606-10-50-12. •If applicable, specify which performance obligations are recognized over time. In addition, please clarify your methods used to measure progress and why the methods reflect a faithful depiction of the transfer of the services. Reference ASC 606-10-50- 17 and 18. •Specify which performance obligations are recognized at a point in time. In addition, please clarify the particular point when revenue is recognized. Reference ASC 606-
FirstName LastNameHiroki Totoki Comapany NameSONY CORP January 15, 2020 Page 2 FirstName LastName Hiroki Totoki SONY CORP January 15, 2020 Page 2 10-50-17 and 19. 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 SiSi Cheng at 202-551-5004 or Kevin Stertzel at 202-551-3723 if you have any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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January 15, 2020
Hiroki Totoki
Chief Financial Officer
SONY CORP
7-1, Konan 1-Chome, Minato-Ku
Tokyo 108-0075, Japan
Re:SONY CORP
Form 20-F for Fiscal Year Ended March 31, 2019
File No. 001-06439
Dear Mr. Totoki:
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 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 20-F for Fiscal Year Ended March 31, 2019
Financial Statements
Summary of Significant Accounting Policies
Revenue Recognition, page F-20
1.We note your disclosure that revenues in the HE&S, IP&S, MC and Semiconductors
segments are recognized when (or as) performance obligations are satisfied. Please
address the following and revise your disclosures as appropriate:
•Clarify the nature of the performance obligations in your contracts. Reference ASC
606-10-50-12.
•If applicable, specify which performance obligations are recognized over time. In
addition, please clarify your methods used to measure progress and why the methods
reflect a faithful depiction of the transfer of the services. Reference ASC 606-10-50-
17 and 18.
•Specify which performance obligations are recognized at a point in time. In addition,
please clarify the particular point when revenue is recognized. Reference ASC 606-
FirstName LastNameHiroki Totoki
Comapany NameSONY CORP
January 15, 2020 Page 2
FirstName LastName
Hiroki Totoki
SONY CORP
January 15, 2020
Page 2
10-50-17 and 19.
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 SiSi Cheng at 202-551-5004 or Kevin Stertzel at 202-551-3723 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing