SEC Comment Letter for WOLFSPEED, INC. (WOLF) (CIK 0000895419) (WOLF) — Oct 19, 2010
WOLFSPEED, INC. (WOLF) (CIK 0000895419)
Date: Oct. 19, 2010 · CIK: 0000895419 · Accession: 0000000000-10-061634
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-21154
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE October 19, 2010 John T. Kurtzweil Chief Financial Officer Cree Inc. 4600 Silicon Drive Durham, North Carolina 27703 Re: Cree Inc. Form 10-K for the fiscal year ended June 27, 2010 Filed August 18, 2010 File No. 000-21154
Dear Mr. Kurtzweil: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us w ith information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising 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.
John T. Kurtzweil Cree Inc. October 19, 2010 Page 2 Form 10-K for the Fiscal Year Ended June 27, 2010
Note 2. Basis of Presentation and Summary of Significant Accounting Policies, page 52
1. With respect to your arrangements to perform research and development for others, please tell us how you considered the disclosures required by FASB ASC 730-20-50-1 through 50-3.
2. Please tell us about the nature of the re finement to your global supply chain that caused you to change the functional currency of your international subsidiaries to the US dollar in the fourth quarter of fiscal 2009. Refer to FASB ASC 830-10- 45-7. Note 17. Geographic Information, page 84
3. On pages 4 -5, you discuss your various products such as LED Chips, LED Components, LED lighting, etc. Please te ll us how you considered the disclosures required by FASB ASC 280-10-50-40. 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 all in formation required under the Securities Exchange Act of 1934 and all applicable 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 disclosu re in response to staff comments do not foreclose the Commission from ta king any action with respect to the filing; and ⋅ the company may not assert staff comments as a defense in any proceeding initiated by the Commissi on or any person under the federal securities laws of the United States.
John T. Kurtzweil Cree Inc. October 19, 2010 Page 3 You may contact Praveen Kartholy at ( 202) 551-3778 or Kate Tillan, Assistant Chief Accountant, at (202) 551-3604 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at (202) 551-3602 or Geoffrey Kruczek at (202) 551- 3641 with any other questions. You may also contact me at (202) 551-3671 with any other questions.
Sincerely, /s/Kate Tillan
for
Martin James Senior Assistant Chief Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
October 19, 2010
John T. Kurtzweil Chief Financial Officer Cree Inc. 4600 Silicon Drive Durham, North Carolina 27703
Re: Cree Inc.
Form 10-K for the fiscal year ended June 27, 2010
Filed August 18, 2010 File No. 000-21154
Dear Mr. Kurtzweil:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
Please respond to this letter within ten business days by providing the requested
information or by advising 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.
John T. Kurtzweil
Cree Inc.
October 19, 2010 Page 2 Form 10-K for the Fiscal Year Ended June 27, 2010
Note 2. Basis of Presentation and Summary of Significant Accounting Policies, page 52
1. With respect to your arrangements to perform research and development for others, please tell us how you considered the disclosures required by FASB ASC
730-20-50-1 through 50-3.
2. Please tell us about the nature of the re finement to your global supply chain that
caused you to change the functional currency of your international subsidiaries to
the US dollar in the fourth quarter of fiscal 2009. Refer to FASB ASC 830-10-
45-7.
Note 17. Geographic Information, page 84
3. On pages 4 -5, you discuss your various products such as LED Chips, LED Components, LED lighting, etc. Please te ll us how you considered the disclosures
required by FASB ASC 280-10-50-40.
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 all in formation required under
the Securities Exchange Act of 1934 and all applicable 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 disclosu re in response to staff comments do
not foreclose the Commission from ta king any action with respect to the
filing; and
⋅ the company may not assert staff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.
John T. Kurtzweil
Cree Inc.
October 19, 2010 Page 3
You may contact Praveen Kartholy at ( 202) 551-3778 or Kate Tillan, Assistant
Chief Accountant, at (202) 551-3604 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at (202) 551-3602
or Geoffrey Kruczek at (202) 551- 3641 with any other questions. You may also contact
me at (202) 551-3671 with any other questions.
Sincerely, /s/Kate Tillan
for
Martin James Senior Assistant Chief Accountant