SEC Comment Letter for PTC (PTC) — May 31, 2017
PTC INC.
Date: May 31, 2017 · CIK: 0000857005 · Accession: 0000000000-17-018987
AI Filing Summary & Sentiment
Letter
Mail Stop 4561 May 31, 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 May 22, 2017 response to our comment letter and have the following comment. In our comment s, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this 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 app lies to your facts and circumst ances, 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 May 8, 2017 letter.
Item 15. Exhi bits and Financial Statement Schedules
Consolidated Statements of Operations, page F -4
1. You state in your response to prior comment 1that in future filings you will report cost of license and subscription and cost of support revenue and the associated ma rgins separately. Please tell us whether you are able to apply a reasonable methodology to also separately report the cost of perpetual license from the cost of subscription revenues and their associated margins, which appear to differ based on your respo nse and the disclosures you highlighted in MD&A .
Mr. James Heppelmann PTC Inc. May 31 , 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 hesit ate to contact me at (202) 551 -3499.
Sincerely,
/s/ Kathleen Collins
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Mail Stop 4561 May 31, 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 May 22, 2017 response to our comment letter and have the following comment. In our comment s, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this 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 app lies to your facts and circumst ances, 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 May 8, 2017 letter. Item 15. Exhi bits and Financial Statement Schedules Consolidated Statements of Operations, page F -4 1. You state in your response to prior comment 1that in future filings you will report cost of license and subscription and cost of support revenue and the associated ma rgins separately. Please tell us whether you are able to apply a reasonable methodology to also separately report the cost of perpetual license from the cost of subscription revenues and their associated margins, which appear to differ based on your respo nse and the disclosures you highlighted in MD&A . Mr. James Heppelmann PTC Inc. May 31 , 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 hesit ate to contact me at (202) 551 -3499. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services