SEC Comment Letter for CISCO SYSTEMS, INC. (CSCO) (CIK 0000858877) (CSCO) — Mar 23, 2020
CISCO SYSTEMS, INC. (CSCO) (CIK 0000858877)
Date: March 23, 2020 · CIK: 0000858877 · Accession: 0000000000-20-002513
AI Filing Summary & Sentiment
File numbers found in text: 000-18225
Letter
March 23, 2020 Prat Bhatt SVP, Chief Accounting Officer Cisco Systems, Inc. 170 West Tasman Drive San Jose, California 95134-1706 Re:Cisco Systems, Inc. Form 10-K for the Fiscal Year Ended July 27, 2019 Filed on September 5, 2019 Form 8-K filed February 12, 2020 File No. 000-18225 Dear Mr. Bhatt: We have limited our review of your filing to the financial statement and related disclosures 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 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 applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 8-K filed on February 12, 2020 Ex-99.1 CISCO REPORTS SECOND QUARTER EARNINGS , page 1 1.In your earnings press release, we note your presentation of Non-GAAP Diluted Earnings per Share. Please address the following:
•Please provide a reconciliation of this non-GAAP measure to the most directly comparable GAAP measure, Diluted EPS, in a more prominent manner, such as a tabular presentation, in accordance with Item 10(e)(1)(i) of Regulation S-K. •We note you provide a summary statement that Non-GAAP EPS increased 5% year over year without equally prominent disclosure of the comparable GAAP EPS measures. Please revise accordingly. Reference is made to Question 102.10 of our Non-GAAP Financial Measures Compliance & Disclosure Interpretations. •Please revise your future non-GAAP presentations, including disclosures filed in quarterly earnings releases on Form 8-K, accordingly.
FirstName LastNamePrat Bhatt Comapany NameCisco Systems, Inc. March 23, 2020 Page 2 FirstName LastName Prat Bhatt Cisco Systems, Inc. March 23, 2020 Page 2
In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Becky Chow, Staff Accountant, at (202) 551-6524 or Craig Wilson, Senior Advisor, at (202) 551-3226 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
Show Raw Text
March 23, 2020
Prat Bhatt
SVP, Chief Accounting Officer
Cisco Systems, Inc.
170 West Tasman Drive
San Jose, California 95134-1706
Re:Cisco Systems, Inc.
Form 10-K for the Fiscal Year Ended July 27, 2019
Filed on September 5, 2019
Form 8-K filed February 12, 2020
File No. 000-18225
Dear Mr. Bhatt:
We have limited our review of your filing to the financial statement and related
disclosures 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 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 applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 8-K filed on February 12, 2020
Ex-99.1 CISCO REPORTS SECOND QUARTER EARNINGS , page 1
1.In your earnings press release, we note your presentation of Non-GAAP Diluted Earnings
per Share. Please address the following:
•Please provide a reconciliation of this non-GAAP measure to the most directly
comparable GAAP measure, Diluted EPS, in a more prominent manner, such as a
tabular presentation, in accordance with Item 10(e)(1)(i) of Regulation S-K.
•We note you provide a summary statement that Non-GAAP EPS increased 5% year
over year without equally prominent disclosure of the comparable GAAP EPS
measures. Please revise accordingly. Reference is made to Question 102.10 of our
Non-GAAP Financial Measures Compliance & Disclosure Interpretations.
•Please revise your future non-GAAP presentations, including disclosures filed in
quarterly earnings releases on Form 8-K, accordingly.
FirstName LastNamePrat Bhatt
Comapany NameCisco Systems, Inc.
March 23, 2020 Page 2
FirstName LastName
Prat Bhatt
Cisco Systems, Inc.
March 23, 2020
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Becky Chow, Staff Accountant, at (202) 551-6524 or Craig Wilson,
Senior Advisor, at (202) 551-3226 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology