SEC Comment Letter for ASML HOLDING NV (ASML, ASMLF) (CIK 0000937966) (ASML) — May 8, 2020
ASML HOLDING NV (ASML, ASMLF) (CIK 0000937966)
Date: May 8, 2020 · CIK: 0000937966 · Accession: 0000000000-20-004038
AI Filing Summary & Sentiment
File numbers found in text: 001-33463
Letter
United States securities and exchange commission logo May 7, 2020 Roger J.M. Dassen Chief Financial Officer ASML Holding N.V. De Run 6501 5504 DR Veldhoven The Netherlands Re:ASML Holding N.V. Form 20-F for Fiscal Year Ended December 31, 2019 Filed February 12, 2020 File No. 001-33463 Dear Mr. Dassen: We have reviewed your filing 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 20-F for Fiscal Year Ended December 31, 2019 Notes to the Consolidated Financial Statements Revenue from contracts with customers, page 141 1.You disclose that transfer of control and recognition of revenue occurs for new system sales upon either delivery or acceptance of the system. Please tell us how you considered whether control transfers over time as these systems appear to include specialized equipment and it is unclear whether you have an enforceable right to payment for performance completed to date. Further, expand your disclosures to clarify these terms. Refer to ASC 606-10-25-27.
FirstName LastNameRoger J.M. Dassen Comapany NameASML Holding N.V. May 7, 2020 Page 2 FirstName LastName Roger J.M. Dassen ASML Holding N.V. May 7, 2020 Page 2 2.You indicate that time based software licenses and related services are sold together, not considered individually distinct, and the transfer of control takes place over the license term. Please tell us the nature of these related services and explain why they are not distinct from the software license. Further, tell us the amount of revenue recognized for these arrangements for each period presented and, to the extent material, revise your disclosures accordingly. Refer to ASC 606-10-25-21. 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Melissa Kindelan, Senior Staff Accountant, at 202-551-3564 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
May 7, 2020
Roger J.M. Dassen
Chief Financial Officer
ASML Holding N.V.
De Run 6501
5504 DR Veldhoven
The Netherlands
Re:ASML Holding N.V.
Form 20-F for Fiscal Year Ended December 31, 2019
Filed February 12, 2020
File No. 001-33463
Dear Mr. Dassen:
We have reviewed your filing 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 20-F for Fiscal Year Ended December 31, 2019
Notes to the Consolidated Financial Statements
Revenue from contracts with customers, page 141
1.You disclose that transfer of control and recognition of revenue occurs for new system
sales upon either delivery or acceptance of the system. Please tell us how you considered
whether control transfers over time as these systems appear to include specialized
equipment and it is unclear whether you have an enforceable right to payment for
performance completed to date. Further, expand your disclosures to clarify these terms.
Refer to ASC 606-10-25-27.
FirstName LastNameRoger J.M. Dassen
Comapany NameASML Holding N.V.
May 7, 2020 Page 2
FirstName LastName
Roger J.M. Dassen
ASML Holding N.V.
May 7, 2020
Page 2
2.You indicate that time based software licenses and related services are sold together, not
considered individually distinct, and the transfer of control takes place over the license
term. Please tell us the nature of these related services and explain why they are not
distinct from the software license. Further, tell us the amount of revenue recognized for
these arrangements for each period presented and, to the extent material, revise your
disclosures accordingly. Refer to ASC 606-10-25-21.
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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Melissa
Kindelan, Senior Staff Accountant, at 202-551-3564 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology