SEC Comment Letter for BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725) (BSX) — Apr 9, 2015
BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725)
Date: April 9, 2015 · CIK: 0000885725 · Accession: 0000000000-15-020477
AI Filing Summary & Sentiment
Reasoning
Letter
April 9, 2015 Via E -mail Mr. Daniel J. Brennan Executive Vice President and Chief Financial Officer Boston Scientific Corporation 300 Boston Scientific Way Marlborough, Massachusetts 01752
Re: Boston Scientific Corporation Form 10-K for the Year Ended Dec ember 31, 2014 Filed February 25, 2015 File No. 001 -11083
Dear Mr. Brennan :
We have limited our review of your filing to the financial statements 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 busine ss days by providing the requested information or advis e 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 10 -K for the Year Ended December 31, 2014
Item 8. Financial Statements
Consolidated Statements of Comprehensive Income (Loss), page 65
1. Your consolidated statements of comprehensive income (loss) are on page 65 while your consolidated stateme nts of operations are on page 62. In future filings, to comply with FASB ASC 220 -10-45-1 through 45 -1B, pleas e either report comprehensive income in a single continuous financial statement or in two separate but consecutive financial statements. Refer t o the examples provided at ASC 220 -10-55.
Mr. Daniel Brennan Boston Scientific Corporation April 9 , 2015 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicabl e Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Julie Sherman at (202) 551 -3640 or Kate Tillan, Assistant Chief Accountant, at (202) 551 -3604 if you have questions regarding comments on the financial statements and related matters. You may also contact me at (202) 551 -3671 with any questions.
Sincer ely,
/s/ Kate Tillan for
Martin James Senior Assistant Chief Accountant
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April 9, 2015 Via E -mail Mr. Daniel J. Brennan Executive Vice President and Chief Financial Officer Boston Scientific Corporation 300 Boston Scientific Way Marlborough, Massachusetts 01752 Re: Boston Scientific Corporation Form 10-K for the Year Ended Dec ember 31, 2014 Filed February 25, 2015 File No. 001 -11083 Dear Mr. Brennan : We have limited our review of your filing to the financial statements 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 busine ss days by providing the requested information or advis e 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 10 -K for the Year Ended December 31, 2014 Item 8. Financial Statements Consolidated Statements of Comprehensive Income (Loss), page 65 1. Your consolidated statements of comprehensive income (loss) are on page 65 while your consolidated stateme nts of operations are on page 62. In future filings, to comply with FASB ASC 220 -10-45-1 through 45 -1B, pleas e either report comprehensive income in a single continuous financial statement or in two separate but consecutive financial statements. Refer t o the examples provided at ASC 220 -10-55. Mr. Daniel Brennan Boston Scientific Corporation April 9 , 2015 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicabl e Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Julie Sherman at (202) 551 -3640 or Kate Tillan, Assistant Chief Accountant, at (202) 551 -3604 if you have questions regarding comments on the financial statements and related matters. You may also contact me at (202) 551 -3671 with any questions. Sincer ely, /s/ Kate Tillan for Martin James Senior Assistant Chief Accountant