SEC Comment Letter for UNISYS CORP (UIS) (CIK 0000746838) (UIS) — Jul 31, 2015
UNISYS CORP (UIS) (CIK 0000746838)
Date: July 31, 2015 · CIK: 0000746838 · Accession: 0000000000-15-039594
AI Filing Summary & Sentiment
Letter
July 31, 2015 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, 2014 Filed February 23, 2015 Form 10 -Q for the Quarterly Period Ended March 31, 2015 Filed April 30, 2015 File No. 001 -08729
Dear Ms. Haugen :
We have reviewed your July 10, 2015 response to our comment letter and 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 comment 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 our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional co mments. Unless we note otherwise, our references to prior comments are to comments in our June 29, 2015 letter.
Form 10 -Q for the Quarterly Period Ended March 31, 2015
Notes to Consolidated Financial Statements
Note e. Segment Information, p age 9
1. We note your response to prior comment 3 and expectation that were a Step 2 goodwill analysis required, the result would indicate no impairment of the Services segment goodwill recorded at December 31, 2014. Since a Step 2 analysis of goodwill of t he Services segment, if required, would be performed at the reporting unit level, please document for us the results of each respective reporting unit’s goodwill impairment assessment you performed pursuant to ASC 350 -20-35-3F through 35 -3G, with considera tion of the factors in ASC 350 -20-35-3C(a) through (g).
Ms. Janet Brutschea Haugen Unisys Corporation July 31, 2015 Page 2
You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 if you have questions regarding comments on the financial statements and related matters. If you have any other questions, please contact Jeff Kauten, Staff Attorney, at (202) 551 -3447 or Katherine Wray, Staff Attorney at (202) 551 -3483 . If you require further assistance, do not hesit ate to contact me at (202) 551 -3226 .
Sincerely,
/s/ Kathleen Collins (for CDW)
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July 31, 2015 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, 2014 Filed February 23, 2015 Form 10 -Q for the Quarterly Period Ended March 31, 2015 Filed April 30, 2015 File No. 001 -08729 Dear Ms. Haugen : We have reviewed your July 10, 2015 response to our comment letter and 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 comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional co mments. Unless we note otherwise, our references to prior comments are to comments in our June 29, 2015 letter. Form 10 -Q for the Quarterly Period Ended March 31, 2015 Notes to Consolidated Financial Statements Note e. Segment Information, p age 9 1. We note your response to prior comment 3 and expectation that were a Step 2 goodwill analysis required, the result would indicate no impairment of the Services segment goodwill recorded at December 31, 2014. Since a Step 2 analysis of goodwill of t he Services segment, if required, would be performed at the reporting unit level, please document for us the results of each respective reporting unit’s goodwill impairment assessment you performed pursuant to ASC 350 -20-35-3F through 35 -3G, with considera tion of the factors in ASC 350 -20-35-3C(a) through (g). Ms. Janet Brutschea Haugen Unisys Corporation July 31, 2015 Page 2 You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 if you have questions regarding comments on the financial statements and related matters. If you have any other questions, please contact Jeff Kauten, Staff Attorney, at (202) 551 -3447 or Katherine Wray, Staff Attorney at (202) 551 -3483 . If you require further assistance, do not hesit ate to contact me at (202) 551 -3226 . Sincerely, /s/ Kathleen Collins (for CDW) Craig D. Wilson Senior Assistant Chief Accountant