SEC Comment Letter for UNISYS CORP (UIS) (CIK 0000746838) (UIS) — Mar 26, 2008
UNISYS CORP (UIS) (CIK 0000746838)
Date: March 26, 2008 · CIK: 0000746838 · Accession: 0000000000-08-015731
AI Filing Summary & Sentiment
Letter
Room 4561 March 26, 2008 Mr. Joseph W. McGrath Chief Executive Officer Unisys Corporation Unisys Way Blue Bell, PA 19424 Re: Unisys Corporation Form 8-K Filed Ma rch 20, 2008 File No. 1-8729
Dear Mr.McGrath,
We have reviewed the above referenced filing and have the following comment. Please note that we have limited our review to the matters addr essed in the comment below. If indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the tele phone numbers at the en d of this letter.
Form 8-K Filed March 20, 2008
General 1. We have read the disclosures contained in the Exhibit 16 letter. Confirm to us that you consulted with representatives of KPMG to discuss revenue recognition matters. In addition, tell us who particip ated in these meetings and describe the content of the discussions.
Mr. Joseph W. McGrath Unisys Corporation March 26, 2008 Page 2 Please respond to this comment within fi ve 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 Regulat ion S-T. If you amend your filings, you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter with your amendment that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional commen ts after reviewing your amendment and response to our comment. We urge all persons who are responsi ble for the accuracy an d adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comment on your filing. You may contact Marc Thomas at ( 202) 551-3452 or me at (202) 551-3451 if you have any questions regard ing the above comment. S i n c e r e l y , Mark Kronforst Accounting Branch Chief
Mr. Joseph W. McGrath Unisys Corporation March 26, 2008 Page 3
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Room 4561
March 26, 2008
Mr. Joseph W. McGrath Chief Executive Officer Unisys Corporation Unisys Way
Blue Bell, PA 19424
Re: Unisys Corporation
Form 8-K Filed Ma rch 20, 2008
File No. 1-8729
Dear Mr.McGrath,
We have reviewed the above referenced filing and have the following comment.
Please note that we have limited our review to the matters addr essed in the comment
below. If indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your
explanation. In our comment, we may ask you to provide us with supplemental
information so we may better understand your disclosure. After reviewing this
information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the tele phone numbers at the en d of this letter.
Form 8-K Filed March 20, 2008
General
1. We have read the disclosures contained in the Exhibit 16 letter. Confirm to us
that you consulted with representatives of KPMG to discuss revenue recognition
matters. In addition, tell us who particip ated in these meetings and describe the
content of the discussions.
Mr. Joseph W. McGrath
Unisys Corporation
March 26, 2008 Page 2
Please respond to this comment within fi ve 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 Regulat ion S-T. If you amend your filings, you
may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter with your amendment that keys your response to our
comment and provides any requested information. Detailed cover letters greatly facilitate
our review. Please understand that we may have additional commen ts after reviewing
your amendment and response to our comment. We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
You may contact Marc Thomas at ( 202) 551-3452 or me at (202) 551-3451 if
you have any questions regard ing the above comment.
S i n c e r e l y , Mark Kronforst Accounting Branch Chief
Mr. Joseph W. McGrath
Unisys Corporation March 26, 2008 Page 3