SEC Comment Letter for Apple (AAPL) — Jul 19, 2011
Apple Inc.
Date: July 19, 2011 · CIK: 0000320193 · Accession: 0000000000-11-043806
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-10030
Referenced dates: June 28, 2011
Letter
July 19, 2011 Via E-mail Mr. Peter Oppenheimer Senior Vice President and Chief Financial Officer Apple, Inc. 1 Infinite Loop Cupertino, California 95014 Re: Apple, Inc. Form 10-Q for the Quarter Ended March 26, 2011 Filed April 21, 2011 File No. 000-10030
Dear Mr. Oppenheimer: We have reviewed your letter dated Ju ly 12, 2011 in connection with the above- referenced 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 amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they refer to our letter dated June 28, 2011
Form 10-Q for the Quarter Ended March 26, 2011
Note 6. Commitments and Contingencies
Contingencies, page 18
1. Please describe in further detail the terms, a rrangements, obligations and rights associated with the Settlement Agreement and Patent License Agreement entered into between the company and Nokia. Also, describe for us each element of these Agreements (i.e. settlement portion, past usage, future usag e, etc.). Tell us how you considered the allocation guidance of ASC 605-25-25, by anal ogy, with regards to bifurcating such elements and tell us how you determined the value for each element. In addition, explain further how your allocation of these Agreements amongst the various elements impacts
Mr. Peter Oppenheimer Apple, Inc. July 19, 2011 Page 2
the timing of your expense recognition and tell us what impact, if any, such timing had on your materiality assessment for this settlement.
You may contact Megan Akst, Staff Accountant, at (202) 551-3407 or me at (202) 551- 3499 if you have questions. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief
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July 19, 2011 Via E-mail Mr. Peter Oppenheimer Senior Vice President and Chief Financial Officer Apple, Inc. 1 Infinite Loop Cupertino, California 95014 Re: Apple, Inc. Form 10-Q for the Quarter Ended March 26, 2011 Filed April 21, 2011 File No. 000-10030 Dear Mr. Oppenheimer: We have reviewed your letter dated Ju ly 12, 2011 in connection with the above- referenced 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 amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they refer to our letter dated June 28, 2011 Form 10-Q for the Quarter Ended March 26, 2011 Note 6. Commitments and Contingencies Contingencies, page 18 1. Please describe in further detail the terms, a rrangements, obligations and rights associated with the Settlement Agreement and Patent License Agreement entered into between the company and Nokia. Also, describe for us each element of these Agreements (i.e. settlement portion, past usage, future usag e, etc.). Tell us how you considered the allocation guidance of ASC 605-25-25, by anal ogy, with regards to bifurcating such elements and tell us how you determined the value for each element. In addition, explain further how your allocation of these Agreements amongst the various elements impacts Mr. Peter Oppenheimer Apple, Inc. July 19, 2011 Page 2 the timing of your expense recognition and tell us what impact, if any, such timing had on your materiality assessment for this settlement. You may contact Megan Akst, Staff Accountant, at (202) 551-3407 or me at (202) 551- 3499 if you have questions. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief