SEC Comment Letter for UNISYS CORP (UIS) (CIK 0000746838) (UIS) — Aug 15, 2014
UNISYS CORP (UIS) (CIK 0000746838)
Date: Aug. 15, 2014 · CIK: 0000746838 · Accession: 0000000000-14-041487
AI Filing Summary & Sentiment
Referenced dates: August 1, 2014, July 22, 2014
Letter
August 15 , 2014 Via E -mail Ms. Janet Brutschea Haugen Senior Vice President and 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, 2013 Filed February 24, 2014 File No. 001 -08729
Dear Ms. Haugen :
We have reviewed your letter dated August 1, 2014 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 informatio n, or by advising us when you will provide the requested 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 amendme nt 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 July 22, 2014 .
Item 8. Financial Statements and Supplementary Data (Incorporated by reference from the Unisys 2013 Annual Report to Stockholders, Exhibit 13)
Notes to Consolidated Financial Statements
Note 4. Goodwill, page 25
1. We note your response to prior comment 2. Please provide us with your eva luation of ASC 350 -20-35-3F through 35 -3G as well as your consideration of the factors in ASC 350-20-35-3C(a) through (g).
Ms. Janet Brutschea Haugen Unisys Corporation August 15 , 2014 Page 2
You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 or Christine Davis, Assistant Chief Accountant 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
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August 15 , 2014 Via E -mail Ms. Janet Brutschea Haugen Senior Vice President and 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, 2013 Filed February 24, 2014 File No. 001 -08729 Dear Ms. Haugen : We have reviewed your letter dated August 1, 2014 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 informatio n, or by advising us when you will provide the requested 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 amendme nt 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 July 22, 2014 . Item 8. Financial Statements and Supplementary Data (Incorporated by reference from the Unisys 2013 Annual Report to Stockholders, Exhibit 13) Notes to Consolidated Financial Statements Note 4. Goodwill, page 25 1. We note your response to prior comment 2. Please provide us with your eva luation of ASC 350 -20-35-3F through 35 -3G as well as your consideration of the factors in ASC 350-20-35-3C(a) through (g). Ms. Janet Brutschea Haugen Unisys Corporation August 15 , 2014 Page 2 You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 or Christine Davis, Assistant Chief Accountant 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