SEC Comment Letter 0000000000-24-010496 to QUANTUM CORP /DE/ (QMCO)
QUANTUM CORP /DE/
Date: Sept. 17, 2024 · CIK: 0000709283 · Accession: 0000000000-24-010496
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13449
Letter
September 17, 2024 Kenneth Gianella Chief Financial Officer Quantum Corporation 224 Airport Parkway, Suite 550 San Jose, CA 95110 Re:Quantum Corporation Form 10-K for Fiscal Year Ended March 31, 2024 Filed June 28, 2024 File No. 001-13449 Dear Kenneth Gianella: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 the comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended March 31, 2024 Explanatory Note 1.We note your disclosure regarding restatement of previously issued financial statements. Please tell us whether a recovery analysis of incentive-based compensation was performed. If no recovery analysis was performed, explain why. Describe the timing and terms of awards received during the fiscal year ended March 31, 2024 and your compensation recovery policy. In addition, please tell us what consideration was given to providing the disclosures pursuant to Item 402(w) of Regulation S-K and filing the company's clawback policy as an exhibit to your Form 10-K pursuant to Item 601(b)(97) of Regulation S-K.
September 17, 2024 Page 2 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. Please contact Joyce Sweeney at 202-551-3449 or Kathleen Collins at 202-551-3499 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc:Brian Cabrera
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September 17, 2024
Kenneth Gianella
Chief Financial Officer
Quantum Corporation
224 Airport Parkway, Suite 550
San Jose, CA 95110
Re:Quantum Corporation
Form 10-K for Fiscal Year Ended March 31, 2024
Filed June 28, 2024
File No. 001-13449
Dear Kenneth Gianella:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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
the comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended March 31, 2024
Explanatory Note
1.We note your disclosure regarding restatement of previously issued financial statements.
Please tell us whether a recovery analysis of incentive-based compensation was
performed. If no recovery analysis was performed, explain why. Describe the timing and
terms of awards received during the fiscal year ended March 31, 2024 and your
compensation recovery policy. In addition, please tell us what consideration was given to
providing the disclosures pursuant to Item 402(w) of Regulation S-K and filing the
company's clawback policy as an exhibit to your Form 10-K pursuant to Item 601(b)(97)
of Regulation S-K.
September 17, 2024
Page 2
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.
Please contact Joyce Sweeney at 202-551-3449 or Kathleen Collins at 202-551-3499 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Brian Cabrera