SEC Company Response from MICROSOFT CORP (MSFT) (CIK 0000789019) (MSFT) — Apr 13, 2011
MICROSOFT CORP (MSFT) (CIK 0000789019)
Date: April 13, 2011 · CIK: 0000789019 · Accession: 0001193125-11-096856
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-14278
Referenced dates: March 29, 2011
Letter
Division of Corporation Finance RE: Microsoft Corporation Form 10-K for the Fiscal Year Ended June 30, 2010 Form 10-Q for the Quarterly Period Ended December 31, 2010 File No. 000-14278
Dear Mr. Wilson,
Pursuant to our phone discussion on April 13, 2011 with Melissa Walsh, we are amending our response to your first comment in your letter dated March 29, 2011 as follows.
Form 10-K for the Fiscal Year Ended June 30, 2010
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Financial Condition, page 33
1. You indicate in your response to prior comment 2 that domestic cash flows from operations continue to be sufficient to fund operating activities and cash commitments for investing and financing activities. Tell us what consideration you gave to specifying the time period that you believe your domestic cash resources will be sufficient, including the short-term and long-term needs and sources of capital. Please refer to Financial Reporting Codification 501.03.a “Liquidity – Capital Resources.”
Response:
We acknowledge the Staff’s comments, and in response, we will specify the time period that we believe our domestic and foreign cash resources will be sufficient, including the short-term and long-term needs and sources of capital. To do this we will disclose that we expect our domestic cash resources will continue to be sufficient to fund our domestic operating activities and cash commitments for investing and financing activities, such as regular quarterly dividends, debt repayment schedules, and material capital expenditures, for at least the next 12 months and thereafter for the foreseeable future. In addition, we will disclose that we expect our foreign cash resources will continue to be sufficient to fund our foreign operating activities and cash commitments for investing activities, such as material capital expenditures, for at least the next 12 months and thereafter for the foreseeable future.
If you have any further questions, please call me at (425) 704-8002 or email me at fbrod@microsoft.com.
Sincerely,
/s/ Frank Brod
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CORRESP 1 filename1.htm Correspondence Letter Microsoft Corporation One Microsoft Way Redmond, WA 98052-6399 Tel 425 882 8080 Fax 425 936 7329 http://www.microsoft.com April 13, 2011 Mr. Craig D. Wilson Senior Assistant Chief Accountant Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 RE: Microsoft Corporation Form 10-K for the Fiscal Year Ended June 30, 2010 Form 10-Q for the Quarterly Period Ended December 31, 2010 File No. 000-14278 Dear Mr. Wilson, Pursuant to our phone discussion on April 13, 2011 with Melissa Walsh, we are amending our response to your first comment in your letter dated March 29, 2011 as follows. Form 10-K for the Fiscal Year Ended June 30, 2010 Management’s Discussion and Analysis of Financial Condition and Results of Operations Financial Condition, page 33 1. You indicate in your response to prior comment 2 that domestic cash flows from operations continue to be sufficient to fund operating activities and cash commitments for investing and financing activities. Tell us what consideration you gave to specifying the time period that you believe your domestic cash resources will be sufficient, including the short-term and long-term needs and sources of capital. Please refer to Financial Reporting Codification 501.03.a “Liquidity – Capital Resources.” Response: We acknowledge the Staff’s comments, and in response, we will specify the time period that we believe our domestic and foreign cash resources will be sufficient, including the short-term and long-term needs and sources of capital. To do this we will disclose that we expect our domestic cash resources will continue to be sufficient to fund our domestic operating activities and cash commitments for investing and financing activities, such as regular quarterly dividends, debt repayment schedules, and material capital expenditures, for at least the next 12 months and thereafter for the foreseeable future. In addition, we will disclose that we expect our foreign cash resources will continue to be sufficient to fund our foreign operating activities and cash commitments for investing activities, such as material capital expenditures, for at least the next 12 months and thereafter for the foreseeable future. If you have any further questions, please call me at (425) 704-8002 or email me at fbrod@microsoft.com. Sincerely, /s/ Frank Brod Frank Brod Corporate Vice President and Chief Accounting Officer cc: Peter Klein, Senior Vice President and Chief Financial Officer John Seethoff, Vice President and Deputy General Counsel Brad Smith, Senior Vice President and General Counsel 1