SEC Comment Letter for FUELCELL ENERGY INC (FCEL, FCELB) (CIK 0000886128) (FCEL) — Oct 29, 2014
FUELCELL ENERGY INC (FCEL, FCELB) (CIK 0000886128)
Date: Oct. 29, 2014 · CIK: 0000886128 · Accession: 0000000000-14-053766
AI Filing Summary & Sentiment
File numbers found in text: 001-14204
Letter
October 29, 2014 Via E -mail Michael S. Bishop Senior Vice President and Chief Financial Officer FuelCell Energy, Inc. 3 Great Pasture Road Danbury, C T 06813
Re: FuelCell Energy, Inc. Form 10 -K for the Fiscal Year e nded October 31, 2013 Filed January 6, 2014 File No. 001-14204
Dear Mr. Bishop :
We have reviewed your response letter dated October 10 , 2014 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 this letter within ten business days by providing the requested information, or by adv ising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended October 31, 2013
Consolidated Statements of Operations and Comprehensive Income (Loss), page 67
1. We note that sales to related parties represent a significant amount of revenues each period. Please revise future filings to separately state related party transactions on the face of your financial statements in accordance with Rule 4 -08(k)(1) of Regulation S -X.
Michael S. Bishop FuelCell Energy, Inc. October 29, 2014 Page 2
Note 1. Nature of Business, Basis of Presentation and Significant Accounting Policies, page 70
Revenue Recognition, page 71
2. We note your response to prior comment 3. Separately priced extended maintenance warranty agreements do not appear to be similar to licen se and royalty revenue arrangements. Accordingly, please revise segment disclosures in future filings to quantify the revenue recorded for extended maintenance warranty agreements separately in accordance with FASB ASC 280 -10-50-40.
You may contact Kevin Kuhar at (202) 551 -3662 or me at (202) 551 -3676 if you have questions regarding comments on the financial statements and related matters. Please do not hesitate to contact Martin James, Senior Assistant Chief Accountant , at (202) 55 1-3671 with any other questions.
Sincerely,
/s/ Brian Cascio
Show Raw Text
October 29, 2014
Via E -mail
Michael S. Bishop
Senior Vice President and Chief Financial Officer
FuelCell Energy, Inc.
3 Great Pasture Road
Danbury, C T 06813
Re: FuelCell Energy, Inc.
Form 10 -K for the Fiscal Year e nded October 31, 2013
Filed January 6, 2014
File No. 001-14204
Dear Mr. Bishop :
We have reviewed your response letter dated October 10 , 2014 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 this letter within ten business days by providing the requested
information, or by adv ising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumstances please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10 -K for the Fiscal Year Ended October 31, 2013
Consolidated Statements of Operations and Comprehensive Income (Loss), page 67
1. We note that sales to related parties represent a significant amount of revenues each
period. Please revise future filings to separately state related party transactions on the
face of your financial statements in accordance with Rule 4 -08(k)(1) of Regulation S -X.
Michael S. Bishop
FuelCell Energy, Inc.
October 29, 2014
Page 2
Note 1. Nature of Business, Basis of Presentation and Significant Accounting Policies, page 70
Revenue Recognition, page 71
2. We note your response to prior comment 3. Separately priced extended maintenance
warranty agreements do not appear to be similar to licen se and royalty revenue
arrangements. Accordingly, please revise segment disclosures in future filings to quantify
the revenue recorded for extended maintenance warranty agreements separately in
accordance with FASB ASC 280 -10-50-40.
You may contact Kevin Kuhar at (202) 551 -3662 or me at (202) 551 -3676 if you have
questions regarding comments on the financial statements and related matters. Please do not
hesitate to contact Martin James, Senior Assistant Chief Accountant , at (202) 55 1-3671 with any
other questions.
Sincerely,
/s/ Brian Cascio
Brian Cascio
Accounting Branch Chief