SEC Comment Letter for MASIMO CORP (MASI) (CIK 0000937556) (MASI) — Jun 15, 2017
MASIMO CORP (MASI) (CIK 0000937556)
Date: June 15, 2017 · CIK: 0000937556 · Accession: 0000000000-17-021094
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33642
Letter
Mail Stop 3030 June 15 , 201 7 Via E -mail Mark P. de Raad Executive Vice President and Chief Financial Officer Masimo Corporation 52 Discovery Irvine, CA 92618
Re: Masimo Corporation Form 10-K for the Fiscal Year Ended December 31, 2016 Filed February 15, 201 7 File No. 001-33642
Dear Mr. de Raad :
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 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 r eviewing your response to these comment s, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31 , 201 6
Item 7A. Quantitative and Qualitative Disclosures about Market Risk, page 74
Foreign Currency Exchange Rate Risk, page 75
1. We note your disclosure that a 10% change in foreign currency exchange rates could have a material effect on your future operating results or cash flows. Consistent with the guidance in Item 305(a)(ii)(A) of Regulation S -K, please revise your future fili ngs to quantify the potential loss that could result from the 10% change in foreign currency exchange rates. In light of your statement that the impact would depend on the particular currency and the direction of the change, consider quantifying the potential impact of a change in each of the currencies you have identified.
Mark P. de Raad Masimo Corporation June 15, 2017 Page 2
Note 7. Property and Equipment , page F -25
2. We note that you reclassified approximately $6.4 million out of construction -in-progress during fiscal 2016, but note that the balance increased at December 31, 2016 when compared with the fiscal 2015 year -end. Please describe and quantify for us the construction projects in progress at December 31 2016.
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 David Burton at (202) 551 -3626 or me at (202) 551 -3671 with any questions.
Sincerely,
/s/ Martin James
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Mail Stop 3030 June 15 , 201 7 Via E -mail Mark P. de Raad Executive Vice President and Chief Financial Officer Masimo Corporation 52 Discovery Irvine, CA 92618 Re: Masimo Corporation Form 10-K for the Fiscal Year Ended December 31, 2016 Filed February 15, 201 7 File No. 001-33642 Dear Mr. de Raad : 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 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 r eviewing your response to these comment s, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31 , 201 6 Item 7A. Quantitative and Qualitative Disclosures about Market Risk, page 74 Foreign Currency Exchange Rate Risk, page 75 1. We note your disclosure that a 10% change in foreign currency exchange rates could have a material effect on your future operating results or cash flows. Consistent with the guidance in Item 305(a)(ii)(A) of Regulation S -K, please revise your future fili ngs to quantify the potential loss that could result from the 10% change in foreign currency exchange rates. In light of your statement that the impact would depend on the particular currency and the direction of the change, consider quantifying the potential impact of a change in each of the currencies you have identified. Mark P. de Raad Masimo Corporation June 15, 2017 Page 2 Note 7. Property and Equipment , page F -25 2. We note that you reclassified approximately $6.4 million out of construction -in-progress during fiscal 2016, but note that the balance increased at December 31, 2016 when compared with the fiscal 2015 year -end. Please describe and quantify for us the construction projects in progress at December 31 2016. 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 David Burton at (202) 551 -3626 or me at (202) 551 -3671 with any questions. Sincerely, /s/ Martin James Martin James Senior Assistant Chief Accountant Office of Electronics and Machinery