SEC Comment Letter for Johnson Controls International plc (JCI) (CIK 0000833444) (JCI) — May 28, 2015
Johnson Controls International plc (JCI) (CIK 0000833444)
Date: May 28, 2015 · CIK: 0000833444 · Accession: 0000000000-15-028572
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13836
Letter
May 28 , 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 March 27, 2015 Filed April 24, 2015 Response Dated May 4, 2015 File No. 001-13836
Dear Mr. Nayar :
We have reviewed your May 4 , 2015 response to our comment letter and have the following comme nt. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
Please respond to th is 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 appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response t o this comment, we may have additional comments. Unless we note otherwise, our reference to our prior comment is to our April 17 , 2015 letter.
Form 10 -Q for the Fiscal Quarter Ended March 27, 2015
Liquidity and Capital Resources, page 55
1. We note your response to comment 2 and your disclosure. Although you identified significant asbestos commitments impacting your liquidity, please expand to discuss your expected material changes in the mix and relative cost of your capital resources or anticipated sou rces of funds to fulfill such obligations. In this regard, we note that most of your cash, including expected proceeds from divestitures, appears to have been committed towards stock repurchases, dividends and acquisitions. Refer to Item 303(a)(2)(ii) o f Regulation S -K.
Mr. Arun Nayar Tyco International plc May 28 , 2015 Page 2
You may contact Kathryn Jacobson, Senior 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/ Terry French for
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May 28 , 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 March 27, 2015 Filed April 24, 2015 Response Dated May 4, 2015 File No. 001-13836 Dear Mr. Nayar : We have reviewed your May 4 , 2015 response to our comment letter and have the following comme nt. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. Please respond to th is 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 appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response t o this comment, we may have additional comments. Unless we note otherwise, our reference to our prior comment is to our April 17 , 2015 letter. Form 10 -Q for the Fiscal Quarter Ended March 27, 2015 Liquidity and Capital Resources, page 55 1. We note your response to comment 2 and your disclosure. Although you identified significant asbestos commitments impacting your liquidity, please expand to discuss your expected material changes in the mix and relative cost of your capital resources or anticipated sou rces of funds to fulfill such obligations. In this regard, we note that most of your cash, including expected proceeds from divestitures, appears to have been committed towards stock repurchases, dividends and acquisitions. Refer to Item 303(a)(2)(ii) o f Regulation S -K. Mr. Arun Nayar Tyco International plc May 28 , 2015 Page 2 You may contact Kathryn Jacobson, Senior 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/ Terry French for Carlos Pacho Senior Assistant Chief Accountant cc: Judith Reinsdorf – General Counsel