SEC Comment Letter for Johnson Controls International plc (JCI) (CIK 0000833444) (JCI) — Apr 17, 2015
Johnson Controls International plc (JCI) (CIK 0000833444)
Date: April 17, 2015 · CIK: 0000833444 · Accession: 0000000000-15-021693
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13836
Letter
April 17 , 2015 Mr. Arun Nayar Executive Vice President and Chief Financial Officer Tyco International plc Unit 1202 Building 1000 City Gate Mahon, Cork Ireland
Re: Tyco International plc Form 10-K for the Fiscal Year Ended September 26, 2014 Filed November 14, 2014 Form 10 -Q for the Fiscal Quarter Ended December 26, 2014 Filed January 30, 2015 Response Dated March 24, 2015 File No. 001-13836
Dear Mr. Nayar :
We have reviewed your March 24, 2015 response to our comment letter and have the following comments. In our comments, we ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busin ess days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to thes e comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 13, 2015 letter.
Form 10 -K for the Fiscal Year Ended September 26, 2014
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 38
1. Please tell us and disclose the significant components of cost of product sales, cost of services, and selling, general and administrati ve expenses. In this regard, we note certain components of your selling, general and administrative expenses as disclosed in the notes to the financial statements and your proxy statement.
Mr. Arun Nayar Tyco International plc April 17 , 2015 Page 2
Form 10 -Q for the Fiscal Quarter Ended December 26, 2014
Liquidity and Capital Resources, page 46
2. We note your response to comment 1. Per your statement your “asbestos liabilities are expected to ultimately be settled in cash.” Accordingly, please discuss the liquidity impact of such cash settlements in futur e filings . In this regard, we note that your expected cash outlay for asbestos claims settlements during FY 2015 appears to be significant in relation to your cash balance and your cash flows from operating activities.
You may contact Kathryn Jacobson, S enior Staff Accountant at (202) -551-3365, Dean Suehiro , Senior Staff Accountant, at (202) 551 -3384 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Robert S. Littlepage, for
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April 17 , 2015 Mr. Arun Nayar Executive Vice President and Chief Financial Officer Tyco International plc Unit 1202 Building 1000 City Gate Mahon, Cork Ireland Re: Tyco International plc Form 10-K for the Fiscal Year Ended September 26, 2014 Filed November 14, 2014 Form 10 -Q for the Fiscal Quarter Ended December 26, 2014 Filed January 30, 2015 Response Dated March 24, 2015 File No. 001-13836 Dear Mr. Nayar : We have reviewed your March 24, 2015 response to our comment letter and have the following comments. In our comments, we ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busin ess days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to thes e comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 13, 2015 letter. Form 10 -K for the Fiscal Year Ended September 26, 2014 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 38 1. Please tell us and disclose the significant components of cost of product sales, cost of services, and selling, general and administrati ve expenses. In this regard, we note certain components of your selling, general and administrative expenses as disclosed in the notes to the financial statements and your proxy statement. Mr. Arun Nayar Tyco International plc April 17 , 2015 Page 2 Form 10 -Q for the Fiscal Quarter Ended December 26, 2014 Liquidity and Capital Resources, page 46 2. We note your response to comment 1. Per your statement your “asbestos liabilities are expected to ultimately be settled in cash.” Accordingly, please discuss the liquidity impact of such cash settlements in futur e filings . In this regard, we note that your expected cash outlay for asbestos claims settlements during FY 2015 appears to be significant in relation to your cash balance and your cash flows from operating activities. You may contact Kathryn Jacobson, S enior Staff Accountant at (202) -551-3365, Dean Suehiro , Senior Staff Accountant, at (202) 551 -3384 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Robert S. Littlepage, for Carlos Pacho Senior Assistant Chief Accountant cc: Judith Reinsdorf – General Counsel