SEC Comment Letter 0000000000-23-010126 to UNISYS CORP (UIS)
UNISYS CORP
Date: Sept. 13, 2023 · CIK: 0000746838 · Accession: 0000000000-23-010126
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08729
Letter
United States securities and exchange commission logo September 13, 2023 Debra McCann Executive Vice President and Chief Financial Officer Unisys Corporation 801 Lakeview Drive, Suite 100 Blue Bell, Pennsylvania 19422 Re:Unisys Corporation Definitive Proxy Statement on Schedule 14A Filed March 24, 2023 File No. 001-08729 Dear Debra McCann: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comments. Please respond to these comments by confirming that you will revise your future proxy disclosures in accordance with the topics discussed below. Definitive Proxy Statement on Schedule 14A filed March 24, 2023 Pay versus Performance, page 59 1.Please ensure that the graphic under the heading "Description of Relationship Between Company TSR and Peer Group TSR" is correctly labeled to indicate the relevant fiscal years shown in the graphic. 2.We note that you have included Non-GAAP Operating Profit as your Company-Selected Measure pursuant to Regulation S-K Item 402(v)(2)(vi). Please include your Company- Selected Measure in the Tabular List provided pursuant to Regulation S-K Item 402(v)(6).
FirstName LastNameDebra McCann Comapany NameUnisys Corporation September 13, 2023 Page 2 FirstName LastName Debra McCann Unisys Corporation September 13, 2023 Page 2 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 Jane Park at 202-551-7439 or Jennifer Zepralka at 202-551-2243 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program
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United States securities and exchange commission logo
September 13, 2023
Debra McCann
Executive Vice President and Chief Financial Officer
Unisys Corporation
801 Lakeview Drive, Suite 100
Blue Bell, Pennsylvania 19422
Re:Unisys Corporation
Definitive Proxy Statement on Schedule 14A
Filed March 24, 2023
File No. 001-08729
Dear Debra McCann:
We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comments. Please respond to these comments by confirming that you
will revise your future proxy disclosures in accordance with the topics discussed below.
Definitive Proxy Statement on Schedule 14A filed March 24, 2023
Pay versus Performance, page 59
1.Please ensure that the graphic under the heading "Description of Relationship Between
Company TSR and Peer Group TSR" is correctly labeled to indicate the relevant fiscal
years shown in the graphic.
2.We note that you have included Non-GAAP Operating Profit as your Company-Selected
Measure pursuant to Regulation S-K Item 402(v)(2)(vi). Please include your Company-
Selected Measure in the Tabular List provided pursuant to Regulation S-K Item 402(v)(6).
FirstName LastNameDebra McCann
Comapany NameUnisys Corporation
September 13, 2023 Page 2
FirstName LastName
Debra McCann
Unisys Corporation
September 13, 2023
Page 2
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 Jane Park at 202-551-7439 or Jennifer Zepralka at 202-551-2243 with any
questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program