SEC Comment Letter for UNISYS CORP (UIS) (CIK 0000746838) (UIS) — Jul 3, 2012
UNISYS CORP (UIS) (CIK 0000746838)
Date: July 3, 2012 · CIK: 0000746838 · Accession: 0000000000-12-034769
AI Filing Summary & Sentiment
Referenced dates: June 18, 2012, June 5, 2012
Letter
July 3, 2012 Via Facsimile Ms. Janet Brutschea Haugen Chief Financial Officer Unisys Corporation 801 Lakeview Drive, Suite 100 Blue Bell, PA 19422
Re: Unisys Corporation Form 10-K for the fiscal year ended December 31, 2011 Filed February 24, 2012 File No. 001 -08729
Dear Ms. Haugen :
We have reviewed you r letter dated June 18, 2012 in connection with the above - referenced filing an d have the following comment. In our comment , 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 advising us when you will provide the r equested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments . Unless otherwise noted, where prior comments are referred to they refer to our letter dated June 5, 2012 .
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 1. Summary of significant accounting policies
Revenue recognition, page 23
1. Your response to prior comment 1 indicates that you use estimated selling price ( “ESP”) to allocate revenue to system integration and consulting, outsourcing and infrastructure services. Considering that you use ESP to allocate these services p lease tell us how you determined that the services have standalone value. In this regard, please tell us whether
Ms. Janet Brutschea Haugen Unisys Corporation July 3, 2012 Page 2
these services are actually sold separately by either you or by a third -party. We refer you to ASC 605 -25-25-5.
You may contact Christine Davis at (202) 551 -3408 if you have questions regarding comments on the financial statements and re lated matters. Please contact me at (202) 551 -3406 with any other questions.
Sincerely,
/s/ Patrick Gilmore
Show Raw Text
July 3, 2012 Via Facsimile Ms. Janet Brutschea Haugen Chief Financial Officer Unisys Corporation 801 Lakeview Drive, Suite 100 Blue Bell, PA 19422 Re: Unisys Corporation Form 10-K for the fiscal year ended December 31, 2011 Filed February 24, 2012 File No. 001 -08729 Dear Ms. Haugen : We have reviewed you r letter dated June 18, 2012 in connection with the above - referenced filing an d have the following comment. In our comment , 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 advising us when you will provide the r equested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments . Unless otherwise noted, where prior comments are referred to they refer to our letter dated June 5, 2012 . Consolidated Financial Statements Notes to Consolidated Financial Statements Note 1. Summary of significant accounting policies Revenue recognition, page 23 1. Your response to prior comment 1 indicates that you use estimated selling price ( “ESP”) to allocate revenue to system integration and consulting, outsourcing and infrastructure services. Considering that you use ESP to allocate these services p lease tell us how you determined that the services have standalone value. In this regard, please tell us whether Ms. Janet Brutschea Haugen Unisys Corporation July 3, 2012 Page 2 these services are actually sold separately by either you or by a third -party. We refer you to ASC 605 -25-25-5. You may contact Christine Davis at (202) 551 -3408 if you have questions regarding comments on the financial statements and re lated matters. Please contact me at (202) 551 -3406 with any other questions. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief