SEC Comment Letter for TRIMBLE INC. (TRMB) (CIK 0000864749) (TRMB) — May 19, 2020
TRIMBLE INC. (TRMB) (CIK 0000864749)
Date: May 19, 2020 · CIK: 0000864749 · Accession: 0000000000-20-004454
AI Filing Summary & Sentiment
File numbers found in text: 001-14845
Letter
United States securities and exchange commission logo May 19, 2020 David Barnes Chief Financial Officer Trimble Inc. 935 Stewart Drive Sunnyvale, CA 94085 Re:Trimble Inc. Form 10-K for the Fiscal Year Ended January 3, 2020 Filed February 28, 2020 File No. 001-14845 Dear Mr. Barnes: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended January 3, 2020 Note 6. Reporting Segment and Geographic Information, page 65 1.Please revise future filings to disclose revenues for the United States, your country of domicile, in accordance with ASC 280-10-50-41(a). Also revise future filings to disclose revenues by geography based on the financial information that is used to produce the general-purpose financial statements in accordance with ASC 280-10-50-41. Exhibits 2.We note that both your Section 906 certifications filed as Exhibits 32.1 and 32.2 identify the incorrect individual within the body of the certification. Please amend the filing to provide corrected Section 906 certifications.
FirstName LastNameDavid Barnes Comapany NameTrimble Inc. May 19, 2020 Page 2 FirstName LastName David Barnes Trimble Inc. May 19, 2020 Page 2 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 Tara Harkins at (202) 551-3639 or Lynn Dicker, Senior Accountant, at (202) 551-3616 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
May 19, 2020
David Barnes
Chief Financial Officer
Trimble Inc.
935 Stewart Drive
Sunnyvale, CA 94085
Re:Trimble Inc.
Form 10-K for the Fiscal Year Ended January 3, 2020
Filed February 28, 2020
File No. 001-14845
Dear Mr. Barnes:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended January 3, 2020
Note 6. Reporting Segment and Geographic Information, page 65
1.Please revise future filings to disclose revenues for the United States, your country of
domicile, in accordance with ASC 280-10-50-41(a). Also revise future filings to disclose
revenues by geography based on the financial information that is used to produce the
general-purpose financial statements in accordance with ASC 280-10-50-41.
Exhibits
2.We note that both your Section 906 certifications filed as Exhibits 32.1 and 32.2 identify
the incorrect individual within the body of the certification. Please amend the filing to
provide corrected Section 906 certifications.
FirstName LastNameDavid Barnes
Comapany NameTrimble Inc.
May 19, 2020 Page 2
FirstName LastName
David Barnes
Trimble Inc.
May 19, 2020
Page 2
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 Tara Harkins at (202) 551-3639 or Lynn Dicker, Senior Accountant, at
(202) 551-3616 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences