SecProbe.io

February 12, 2020
Charles Boynton
Chief Financial Officer
Plantronics, Inc.
345 Encinal Street
Santa Cruz, CA 95060
Re:Plantronics, Inc.
Form 10-K for the Fiscal Year Ended March 30, 2019
Filed May 17, 2019
Form 8-K Filed February 4, 2020
File No. 001-12696
Dear Mr. Boynton:
            We have limited our review of your filing to the financial statements and related
disclosures 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 March 30, 2019
Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
Note 1. Company, page 62
1.You disclose that you operate as one operating segment, that your chief executive officer
is your CODM and that he reviews financial information on a consolidated basis to
evaluate performance.  However, we note that the July 2018 acquisition
of Polycom materially altered your financial position and operations, such that your
product and service offerings have expanded from (i) Enterprise Headsets and (ii)
Consumer Headsets to include (iii) Voice, Video and Content Sharing Solutions as well as
(iv) Support Solutions. Given the integration of Polycom into the entity post
acquisition and the realignments discussed in the filing, please address the following:

 FirstName LastNameCharles Boynton
 Comapany NamePlantronics, Inc.
 February 12, 2020 Page 2
 FirstName LastNameCharles Boynton
Plantronics, Inc.
February 12, 2020
Page 2
•Describe to us how the businesses and operations of Polycom have been integrated
into Plantronics.
•Explain to us the factors you considered in concluding that you continue to operate as
one operating segment pursuant to ASC 280-10-50.
•Tell us whether your four product categories represent business units and describe the
level of financial information available for each beyond net revenues.
•Describe to us the content of the information package that is provided to your CODM
and how often he reviews the information.
•Provide us with an organizational chart of your senior management team that shows
your CEO and each of his direct reports along with a brief description
of their primary areas of responsibilities.
2.Your disclosure appears to indicate that the Voice, Video and Content Sharing Solutions
and the Support Solutions lines represent the legacy businesses of Polycom.  Describe to
us the reporting units used, or you plan to use, to assess impairment of goodwill in your
Fiscal Year 2020 impairment tests. Tell us how you considered your four product lines in
reaching that conclusion. Please refer to ASC 350-20-35-33 through 38.
Note 2. Significant Accounting Policies
Fiscal Year, page 62
3.Please revise your future filings to present your financial statements, including all your
primary financial statements as well as the notes thereto, and all other financial
information in the filings as of and for the periods ended on the actual dates on which your
fiscal years and quarterly periods end.
Note 19. Revenue and Major Customers, page 96
4.Revise your disclosures relating to deferred revenues on page 97 in future filings to briefly
describe the transactions or circumstances that resulted in deferred revenues and explain
how the relationship between the timing of payment from your customer and the
satisfaction of your performance obligation impacts your deferred revenue balances.
Please refer to ASC 606-10-50-9.
Form 8-K Filed February 4, 2020
Exhibit 99.1
Unaudited Reconciliations of GAAP Measures to Non-GAAP Measures, page 10
5.We note that you present a non-GAAP net revenues measure. Please address the
following:

•Explain to us what the deferred revenue purchase accounting adjustment represents,
including a brief description of the transactions that gave rise to the deferred
revenues, how the deferred revenues were treated under purchase accounting, and
what you wish to convey to investors by adding the amount to GAAP revenues.

 FirstName LastNameCharles Boynton
 Comapany NamePlantronics, Inc.
 February 12, 2020 Page 3
 FirstName LastName
Charles Boynton
Plantronics, Inc.
February 12, 2020
Page 3

•Tell us how you considered the guidance in Question 100.04 of the
revised Compliance & Disclosure Interpretations on Non-GAAP Financial Measures
which indicates that non-GAAP measures that substitute individually tailored revenue
recognition and measurement methods for those of GAAP should not be presented in
documents filed or furnished with the Commission or provided elsewhere.
6.Tell us what the adjustment entitled "Purchase accounting amortization" represents.
Identify the balance sheet items being amortized and the related amortization periods.
7.Revise your presentations in future filings to reconcile Adjusted EBITDA to net income
(loss), and not to operating (loss) as noted on page 13.  Please refer to Question 103.02 of
the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
            In closing, 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 Dale Welcome at 202-551-3865 or Martin James, Senior Advisor, at
202-551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing