SEC Comment Letter for MICROSOFT CORP (MSFT) (CIK 0000789019) (MSFT) — Jan 26, 2012
MICROSOFT CORP (MSFT) (CIK 0000789019)
Date: Jan. 26, 2012 · CIK: 0000789019 · Accession: 0000000000-12-004252
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 10, 2012
Letter
CORRECTED January 25, 2012 Via E -mail Frank Brod Corporate Vice President, Finance and Administration Microsoft Corporation One Microsoft Way Redmond, Washington 98052 -6399
Re: Microsoft Corporation Form 10 -K for the Fiscal Year Ended June 30, 201 1 Filed July 28 , 2011 File No. 000 -14278
Dear Mr. Brod :
We have reviewed your letter dated January 10, 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 w ill 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 amendment to your filing and the infor mation 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 December 27 , 2011 .
Form 10 -K for the Fiscal Year Ended June 30, 2011
General
1. You state in your response to prior comment 1 that you have received licenses from BIS to sell certain commercial products to Syria since July 2009. Please tell us whether you have engaged, or intend to engage, in business transactions with Sy ria pursuant to those licenses and, if so, tell us the approximate dollar amounts of any revenues, assets, and liabilities related to Syria since July 2009. In addition, discuss for us the materiality of your business with Syria in qualitative terms that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company’s reputation and share value.
Frank Brod Microsoft Corporation January 25, 2012 Page 2
You may contact Melissa Walsh, Staff Accountant, at (202) 551 -3224 if you have questions regarding comments on the financial statements and re lated matters. Please contact me at (202) 551 -3226 with any other questions .
Sincerely,
/s/ Craig D. Wilson
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CORRECTED
January 25, 2012
Via E -mail
Frank Brod
Corporate Vice President, Finance and Administration
Microsoft Corporation
One Microsoft Way
Redmond, Washington 98052 -6399
Re: Microsoft Corporation
Form 10 -K for the Fiscal Year Ended June 30, 201 1
Filed July 28 , 2011
File No. 000 -14278
Dear Mr. Brod :
We have reviewed your letter dated January 10, 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 w ill 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 amendment to your filing and the infor mation 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 December 27 , 2011 .
Form 10 -K for the Fiscal Year Ended June 30, 2011
General
1. You state in your response to prior comment 1 that you have received licenses from BIS
to sell certain commercial products to Syria since July 2009. Please tell us whether you
have engaged, or intend to engage, in business transactions with Sy ria pursuant to those
licenses and, if so, tell us the approximate dollar amounts of any revenues, assets, and
liabilities related to Syria since July 2009. In addition, discuss for us the materiality of
your business with Syria in qualitative terms that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value.
Frank Brod
Microsoft Corporation
January 25, 2012
Page 2
You may contact Melissa Walsh, Staff Accountant, at (202) 551 -3224 if you have
questions regarding comments on the financial statements and re lated matters. Please contact me
at (202) 551 -3226 with any other questions .
Sincerely,
/s/ Craig D. Wilson
Craig D. Wilson
Sr. Asst. Chief Accountant