SEC Comment Letter for DAKTRONICS (DAKT) — Nov 9, 2017
DAKTRONICS INC /SD/ (DAKT) (CIK 0000915779)
Date: Nov. 9, 2017 · CIK: 0000915779 · Accession: 0000000000-17-039841
AI Filing Summary & Sentiment
Letter
November 9, 2017 Ms. Sheila Anderson Chief Financial Officer Daktronics, Inc. 201 Daktronics Drive Brookings, South Dakota 57006
Re: Daktronics, Inc. Form 10-K for the Fiscal Year Ended April 29, 2017 Filed June 9, 2017 Form 8 -K Filed September 15, 2017 File No. 0 -23246
Dear Ms. Anderson :
We have reviewed your filing an d 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 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 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 April 29, 2017
Statements of Operation s, page 34
1. Your disclosures on page 39 indicate that revenues from services exceeded 10% of net sales for the year ended April 29, 2017. In this regard, please separately present both revenue and costs of revenues from services pursuant to Rule 5 -03 of R egulation S -X.
Form 8 -K Filed September 15, 2017
Exhibit 16.1
2. Pursuant to Item 304(a)(3) of Regulation S -K, it is not clear whether your former accountant agrees with the statements made. It would appear that your former accountant would have the basi s to agree or disagree with at least the statements made in your
Ms. Sheila Anderson Daktronics, Inc. November 9, 2017 Page 2
second and third paragraphs of Item 4.01(a). Exhibit 16.1 indicates in one sentence that it is in agreement with the third paragraph and in another sentence indicates that the former account ant has no basis to agree or disagree with the statements made in the second and third paragraphs. As a result, it is not clear if they agree or disagree with the second and third paragraphs. Please amend your Form 8 -K to provide a revised letter from yo ur former accountant which clearly indicates whether they agree with the statements made in Item 4.01(a).
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 Christopher Ronne , Staff Attorney, at (202) 551 -6156 or, in his absence, Sherry Haywood, Staff Attorney, at (202) 551 -3345 if you have any questions regarding legal matters. Please contact Nudrat Salik, Staff Accountant, at (202) 551 -3692 or, in her absence, me at (202) 551 -3854 if you have q uestions regarding comments on the financial statements and related matters . .
Sincerely,
/s/ Melissa N. Rocha
Show Raw Text
November 9, 2017
Ms. Sheila Anderson
Chief Financial Officer
Daktronics, Inc.
201 Daktronics Drive
Brookings, South Dakota 57006
Re: Daktronics, Inc.
Form 10-K for the Fiscal Year Ended April 29, 2017
Filed June 9, 2017
Form 8 -K
Filed September 15, 2017
File No. 0 -23246
Dear Ms. Anderson :
We have reviewed your filing an d 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 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
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 April 29, 2017
Statements of Operation s, page 34
1. Your disclosures on page 39 indicate that revenues from services exceeded 10% of net
sales for the year ended April 29, 2017. In this regard, please separately present both
revenue and costs of revenues from services pursuant to Rule 5 -03 of R egulation S -X.
Form 8 -K Filed September 15, 2017
Exhibit 16.1
2. Pursuant to Item 304(a)(3) of Regulation S -K, it is not clear whether your former
accountant agrees with the statements made. It would appear that your former accountant
would have the basi s to agree or disagree with at least the statements made in your
Ms. Sheila Anderson
Daktronics, Inc.
November 9, 2017
Page 2
second and third paragraphs of Item 4.01(a). Exhibit 16.1 indicates in one sentence that it
is in agreement with the third paragraph and in another sentence indicates that the former
account ant has no basis to agree or disagree with the statements made in the second and
third paragraphs. As a result, it is not clear if they agree or disagree with the second and
third paragraphs. Please amend your Form 8 -K to provide a revised letter from yo ur
former accountant which clearly indicates whether they agree with the statements made
in Item 4.01(a).
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 Christopher Ronne , Staff Attorney, at (202) 551 -6156 or, in his
absence, Sherry Haywood, Staff Attorney, at (202) 551 -3345 if you have any questions regarding
legal matters. Please contact Nudrat Salik, Staff Accountant, at (202) 551 -3692 or, in her
absence, me at (202) 551 -3854 if you have q uestions regarding comments on the financial
statements and related matters .
.
Sincerely,
/s/ Melissa N. Rocha
Melissa N. Rocha
Senior Assistant Chief Accountant
Office of Manufacturing and Construction