SEC Comment Letter for QUANTUM (QMCO) — Jun 25, 2009
QUANTUM CORP /DE/ (QMCO) (CIK 0000709283)
Date: June 25, 2009 · CIK: 0000709283 · Accession: 0000000000-09-033687
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13449
Referenced dates: June 15, 2009, May 12, 2009
Letter
Mail Stop 4561 J u n e 2 4 , 2 0 0 9 Jon W. Gacek Chief Financial Officer Quantum Corporation 1650 Technology Drive, Suite 800 San Jose, CA 95110
Re: Quantum Corporation Form 10-K for the Fiscal Year Ended March 31, 2008 Filed June 13, 2008 File No. 001-13449
Dear Mr. Gacek:
We have reviewed your response letter dated June 15, 2009 in connection with the above-referenced filing and have the followi ng comments. If indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us w ith supplemental information so we may better understand your disclosure. After re viewing this information, we may raise additional comments. Unless otherwise noted, where prior comments are referred to they refer to our letter dated May 12, 2009.
Form 10-K for the Fiscal Year Ended March 31, 2008
Item 8. Financial Statements and Supplementary Data
Note 3: Summary of Significant Accounting Policies
Service Parts for Maintenance, page 59 1. Your response to prior comment number 2 indicates you have “modeled a decline in value” of service parts based on the slow down of their usage. However, we note the following: Your statements on page 4 of your response appear to contradict your conclusion that your service parts have a “modeled decline in value.” In
Jon W. Gacek Quantum Corporation June 24, 2009 Page 2 this regard, you indicate that “iden tical service part numbers…have the same value regardless of their age or pr ior utilization” and “the fair value of two identical refurbished service pa rts that differ only in how long they have previously been used is the same regardless of age”; A “modeled decline in value” does no t appear consistent with your assertion on page 2 of your response th at you believe the loss of utility of your service parts is largel y the result of excess a nd obsolete service parts; and It is unclear how ARB 43 contempl ates a “modeled decline in value.”
Please clarify why a “modeled decline in value” is consistent with the LCM model in ARB 43 and the statements you make elsewhere in your response. 2. Please clarify the time lag between distri bution, return and refurbishment of the service parts as described in your explan ation of service part transactions in response to prior comment number 2. If distribution, return and refurbishment can occur in different reporting periods, pl ease clarify whether there is any impact to your consolidated financial statements for current and prior reporting periods. 3. To the extent the application of ARB 43 does not result in a material difference from the Company’s historical accounting, we will not object to your proposal of prospective application beginning with your Form 10-K for the fiscal year ended March 31, 2009; however, please confirm you intend to present such adjustment as a change in accounting principle. 4. Please provide us with your proposed accounting policy disclosure that incorporates the changes to your accounting for service parts.
* * * * * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing, you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter th at keys your response to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review. Please understand that we may have addi tional comments after reviewing any amendment and your response to our comments.
Jon W. Gacek Quantum Corporation June 24, 2009 Page 3 You may contact Jennifer F ugario, Staff Accountant, at (202) 551-3482, or Mark Shannon, Staff Accountant, at (202) 551-3299 if you have an y questions regarding the above comments. If you need further assi stance, you may contact me at (202) 551-3406.
S i n c e r e l y ,
P a t r i c k G i l m o r e Accounting Branch Chief
Show Raw Text
Mail Stop 4561
J u n e 2 4 , 2 0 0 9
Jon W. Gacek
Chief Financial Officer
Quantum Corporation
1650 Technology Drive, Suite 800
San Jose, CA 95110
Re: Quantum Corporation
Form 10-K for the Fiscal Year Ended March 31, 2008
Filed June 13, 2008
File No. 001-13449
Dear Mr. Gacek:
We have reviewed your response letter dated June 15, 2009 in connection with the
above-referenced filing and have the followi ng comments. If indicated, we think you
should revise your document in response to these comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as deta iled as necessary in your expl anation. In some of our
comments, we may ask you to provide us w ith supplemental information so we may
better understand your disclosure. After re viewing this information, we may raise
additional comments. Unless otherwise noted, where prior comments are referred to they
refer to our letter dated May 12, 2009.
Form 10-K for the Fiscal Year Ended March 31, 2008
Item 8. Financial Statements and Supplementary Data
Note 3: Summary of Significant Accounting Policies
Service Parts for Maintenance, page 59
1. Your response to prior comment number 2 indicates you have “modeled a decline in value” of service parts based on the slow down of their usage. However, we note the following:
Your statements on page 4 of your response appear to contradict your conclusion that your service parts have a “modeled decline in value.” In
Jon W. Gacek
Quantum Corporation
June 24, 2009 Page 2
this regard, you indicate that “iden tical service part numbers…have the
same value regardless of their age or pr ior utilization” and “the fair value
of two identical refurbished service pa rts that differ only in how long they
have previously been used is the same regardless of age”;
A “modeled decline in value” does no t appear consistent with your
assertion on page 2 of your response th at you believe the loss of utility of
your service parts is largel y the result of excess a nd obsolete service parts;
and
It is unclear how ARB 43 contempl ates a “modeled decline in value.”
Please clarify why a “modeled decline in value” is consistent with the LCM
model in ARB 43 and the statements you make elsewhere in your response.
2. Please clarify the time lag between distri bution, return and refurbishment of the
service parts as described in your explan ation of service part transactions in
response to prior comment number 2. If distribution, return and refurbishment
can occur in different reporting periods, pl ease clarify whether there is any impact
to your consolidated financial statements for current and prior reporting periods.
3. To the extent the application of ARB 43 does not result in a material difference
from the Company’s historical accounting, we will not object to your proposal of
prospective application beginning with your Form 10-K for the fiscal year ended March 31, 2009; however, please confirm you intend to present such adjustment
as a change in accounting principle.
4. Please provide us with your proposed accounting policy disclosure that incorporates the changes to your accounting for service parts.
* * * * * * *
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your
filing, you may wish to provide us with marked copies of any amendment to expedite our
review. Please furnish a cover letter th at keys your response to our comments and
provides any requested information. Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
Jon W. Gacek
Quantum Corporation
June 24, 2009 Page 3
You may contact Jennifer F ugario, Staff Accountant, at (202) 551-3482, or Mark
Shannon, Staff Accountant, at (202) 551-3299 if you have an y questions regarding the
above comments. If you need further assi stance, you may contact me at (202) 551-3406.
S i n c e r e l y ,
P a t r i c k G i l m o r e
Accounting Branch Chief