SEC Comment Letter 0000000000-23-001836 to NetApp, Inc. (NTAP) (CIK 0001002047) (NTAP)
NetApp, Inc. (NTAP) (CIK 0001002047)
Date: Feb. 24, 2023 · CIK: 0001002047 · Accession: 0000000000-23-001836
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo February 24, 2023 Michael Berry Executive Vice President and Chief Financial Officer NetApp, Inc. 3060 Olsen Drive San Jose, CA 95128 Re:NetApp, Inc. Form 10-K for the Fiscal Year Ended April 29, 2022 Form 10-Q for the Quarterly Period Ended October 28, 2022 Dear Michael Berry: We have reviewed your February 2, 2023 response to our comment letter and have the following comment. Our comment may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 23, 2023 letter. Form 10-Q for the Quarterly Period Ended October 28, 2022 14. Segment, Geographic, and Significant Customer Information, page 22 1.We note your response to our prior comment one. However, we also note that your business section and MD&A both have qualitative discussions as to the different subcategories of products. In addition, on page 30 you state "support revenues increased in the second quarter and first six months of fiscal 2023 compared to the corresponding periods of the prior year, primarily due to growth in sales of all-flash systems (which carry a higher support dollar content than our other products)." Furthermore, you highlight all- flash array business growth of 2% in your Earnings Slides and Earnings Summary. Given your own disaggregation of revenue streams, please further clarify why you believe these product lines are similar. Your analysis should be detailed and discuss what makes these product lines similar as well as what makes them different.
FirstName LastNameMichael Berry Comapany NameNetApp, Inc. February 24, 2023 Page 2 FirstName LastName Michael Berry NetApp, Inc. February 24, 2023 Page 2 You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Robert Littlepage, Accounting Branch Chief at 202-551-3361 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
February 24, 2023
Michael Berry
Executive Vice President and Chief Financial Officer
NetApp, Inc.
3060 Olsen Drive
San Jose, CA 95128
Re:NetApp, Inc.
Form 10-K for the Fiscal Year Ended April 29, 2022
Form 10-Q for the Quarterly Period Ended October 28, 2022
Dear Michael Berry:
We have reviewed your February 2, 2023 response to our comment letter and have the
following comment. Our comment may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
January 23, 2023 letter.
Form 10-Q for the Quarterly Period Ended October 28, 2022
14. Segment, Geographic, and Significant Customer Information, page 22
1.We note your response to our prior comment one. However, we also note that your
business section and MD&A both have qualitative discussions as to the different
subcategories of products. In addition, on page 30 you state "support revenues increased
in the second quarter and first six months of fiscal 2023 compared to the corresponding
periods of the prior year, primarily due to growth in sales of all-flash systems (which carry
a higher support dollar content than our other products)." Furthermore, you highlight all-
flash array business growth of 2% in your Earnings Slides and Earnings Summary. Given
your own disaggregation of revenue streams, please further clarify why you believe these
product lines are similar. Your analysis should be detailed and discuss what makes these
product lines similar as well as what makes them different.
FirstName LastNameMichael Berry
Comapany NameNetApp, Inc.
February 24, 2023 Page 2
FirstName LastName
Michael Berry
NetApp, Inc.
February 24, 2023
Page 2
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Robert
Littlepage, Accounting Branch Chief at 202-551-3361 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology