SEC Comment Letter for PTC (PTC) — Apr 6, 2017
PTC INC.
Date: April 6, 2017 · CIK: 0000857005 · Accession: 0000000000-17-011866
AI Filing Summary & Sentiment
Letter
Mail Stop 4561 April 6, 2017 Mr. James Heppelmann Chief Executive Officer PTC, Inc. 140 Kendrick Street Needham, MA 02494
Re: PTC Inc. Form 10-K for the Fiscal Year Ended September 30, 2016 Filed November 18, 2016 File No. 000 -18059
Dear Mr. Heppelmann :
We have reviewed your March 16, 2017 response to our comment letter and 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 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 circums tances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 2, 2017 letter .
Item 15. E xhibits and Financial Statement Schedules
Consolidated Statements of Operations, page F -4
1. We note your response to prior comment 2. It remains unclear how you determined that combin ing the cost of both product and services (i.e., support) in cost of software revenue on the face of your consolidated statement of operations co mplies with Rule 5-03(b)(2) of Regulation S-X. Please explain further and clarify how you determined that similar margins are achieved for all products and services . Also, tell us how you considered applying a reasonable allocation methodology to separately reflect the direct cost of both product and service revenues for purposes of complying with this Rule .
Mr. James Heppelmann PTC Inc. April 6, 2017 Page 2
You may contact Megan Akst, Senior Staff Accountant at (202) 551 -3407 if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3499.
Sincerely,
/s/ Kathleen Collins
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Mail Stop 4561 April 6, 2017 Mr. James Heppelmann Chief Executive Officer PTC, Inc. 140 Kendrick Street Needham, MA 02494 Re: PTC Inc. Form 10-K for the Fiscal Year Ended September 30, 2016 Filed November 18, 2016 File No. 000 -18059 Dear Mr. Heppelmann : We have reviewed your March 16, 2017 response to our comment letter and 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 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 circums tances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 2, 2017 letter . Item 15. E xhibits and Financial Statement Schedules Consolidated Statements of Operations, page F -4 1. We note your response to prior comment 2. It remains unclear how you determined that combin ing the cost of both product and services (i.e., support) in cost of software revenue on the face of your consolidated statement of operations co mplies with Rule 5-03(b)(2) of Regulation S-X. Please explain further and clarify how you determined that similar margins are achieved for all products and services . Also, tell us how you considered applying a reasonable allocation methodology to separately reflect the direct cost of both product and service revenues for purposes of complying with this Rule . Mr. James Heppelmann PTC Inc. April 6, 2017 Page 2 You may contact Megan Akst, Senior Staff Accountant at (202) 551 -3407 if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3499. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services