SEC Comment Letter for BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725) (BSX) — Jul 16, 2013
BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725)
Date: July 16, 2013 · CIK: 0000885725 · Accession: 0000000000-13-038704
AI Filing Summary & Sentiment
Reasoning
Referenced dates: July 3, 2013
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE July 16 , 2013 Via E -mail Mr. Jeffrey Capello Executive Vice President and Chief Financial Officer Boston Scientific Corporation One Boston Scientific Place Natick, Massachusetts 01760 -1537
Re: Boston Scientific Corporation Form 10 -K for the F iscal Year E nded December 31 , 2012 Filed February 22, 2013 File No. 001 -11083
Dear Mr. Capello :
We have reviewed your filing and correspondence dated July 3, 2013 and we have the following comment .
Please respond to this letter within ten busine ss days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances , pleas e tell us why in your response.
After reviewing the information you pr ovide in response to this comment , we may have additional comments.
Form 10 -K for the Fiscal Year E nded December 31, 2012
Item 8. Financial Statements
Note D. Goodwill and Other Intangible Assets, page 90
Intangible Asset Impairment Charges, page 94
1. We refer to your response to comment 1 in your letter dated July 3, 2013. In light of the significance of the CRM amortizing intangible assets and your disclosure that those assets are at higher risk of impairment, in future filings please provide expan ded critical accounting policy disclosure in MD&A to describe the substance of your impairment evaluation, as set forth in your response. For
Jeffrey Capello Boston Scientific Corporation July 16 , 2013 Page 2
instance, please describe the key assumptions that are the drivers of your analysis, such as, how you group asset s for purposes of measuring cash flows, the basis for the estimated life of those cash flows and the rationale for future expectations that differ from recent historical experience.
You may contact Praveen Kartholy at (202) 551 -3778 or Gary Todd at (202) 551 - 3605 if you have questions regarding comments on the financial statements and related matters. Please contact Brian Cascio, Accounting Branch Chief, at (202) 551 -3676 with any other questions.
Sincerely,
/s/Gary Todd for
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
July 16 , 2013
Via E -mail
Mr. Jeffrey Capello
Executive Vice President and Chief Financial Officer
Boston Scientific Corporation
One Boston Scientific Place
Natick, Massachusetts 01760 -1537
Re: Boston Scientific Corporation
Form 10 -K for the F iscal Year E nded December 31 , 2012
Filed February 22, 2013
File No. 001 -11083
Dear Mr. Capello :
We have reviewed your filing and correspondence dated July 3, 2013 and we have
the following comment .
Please respond to this letter within ten busine ss days by providing the requested
information or by advising us when you will provide the requested response. If you do
not believe our comment applies to your facts and circumstances , pleas e tell us why in
your response.
After reviewing the information you pr ovide in response to this comment , we may
have additional comments.
Form 10 -K for the Fiscal Year E nded December 31, 2012
Item 8. Financial Statements
Note D. Goodwill and Other Intangible Assets, page 90
Intangible Asset Impairment Charges, page 94
1. We refer to your response to comment 1 in your letter dated July 3, 2013. In light
of the significance of the CRM amortizing intangible assets and your disclosure
that those assets are at higher risk of impairment, in future filings please provide
expan ded critical accounting policy disclosure in MD&A to describe the
substance of your impairment evaluation, as set forth in your response. For
Jeffrey Capello
Boston Scientific Corporation
July 16 , 2013
Page 2
instance, please describe the key assumptions that are the drivers of your analysis,
such as, how you group asset s for purposes of measuring cash flows, the basis for
the estimated life of those cash flows and the rationale for future expectations that
differ from recent historical experience.
You may contact Praveen Kartholy at (202) 551 -3778 or Gary Todd at (202) 551 -
3605 if you have questions regarding comments on the financial statements and related
matters. Please contact Brian Cascio, Accounting Branch Chief, at (202) 551 -3676 with
any other questions.
Sincerely,
/s/Gary Todd for
Brian Cascio
Accounting Branch Ch ief