Correspondence 0001193125-23-022761 from NetApp, Inc. (NTAP) (CIK 0001002047) (NTAP)
NetApp, Inc. (NTAP) (CIK 0001002047)
Date: Feb. 2, 2023 · CIK: 0001002047 · Accession: 0001193125-23-022761
AI Filing Summary & Sentiment
File numbers found in text: 000-27130
Letter
www.netapp.com
408 822 6000 Tel
3060 Olsen Drive
San Jose, CA 95128
United States
February 2, 2023
Via EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-3628
Attn: Robert Littlepage, Accounting Branch Chief
Inessa Kessman, Senior Staff Accountant
Re: NetApp, Inc.
Form 10-K for the Fiscal Year Ended April 29, 2022
Filed June 16, 2022
Form 10-Q for the Quarterly Period Ended October 28, 2022
Filed December 1, 2022
File No. 000-27130
Ladies and Gentlemen:
NetApp, Inc. (the “Company”) submits this letter to you in response to your letter of January 23, 2023, which sets forth a comment of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the above-referenced filings. For your convenience, we have recited the Staff’s comment in italicized, bold type and have followed the comment with our response in regular, un-bold type.
Form 10-Q for the quarterly period ended October 28, 2022
14. Segment, Geographic, and Significant Customer Information, page 22
1. Please disclose revenues from external customers for each product and service or each group of similar products and services in accordance with ASC 280-10-50-40. We note disclosure on page 28 and 30 which refers to various product categories including portfolios that include all-flash, hybrid-flash, and object storage systems.
Response
The Company respectfully acknowledges the Staff’s comment and advises the Staff of the following. In connection with the preparation of our segment financial statement disclosures, we considered ASC-280-10-50-40, which requires disclosure of “revenues from external customers of each product and service or each group of similar products and services unless it is impracticable to do so.” As the guidance does not provide a definition of “similar,” we have relied on an analysis of the facts and circumstances in each of our segments to determine whether the respective products and services revenues in those segments should be combined. In connection with this analysis, we concluded that the revenue line items in our existing reportable segments disclosure reflect appropriate groupings for the purposes of ASC 280-10-50-40. In reaching this conclusion, we analyzed the criteria outlined in ASC 280-10-50-11, and determined that, for the product revenues grouped and services revenues grouped in each segment, the nature of the products or services, the nature of their production processes, the type and class of customers for each, and the methods used to distribute the products and provide the services were similar and therefore should be grouped. For example, all Hybrid Cloud segment products, including all-flash, hybrid-flash and object storage, are storage systems that are regularly sold to customers across the same industries, and are subject to similar manufacturing and research and development processes, sales efforts, and distribution methods. Based on our analysis, we concluded that our segment disclosures provide investors meaningful information about groups of similar products and services in accordance with ASC 280-10-50-40.
* * * * *
We hope that you will find the foregoing responsive to the Staff’s comments. If you have any further questions or comments, please direct those to me at (408) 822-4599 or mike.berry@netapp.com. Thank you for your assistance.
Sincerely,
/s/ Michael Berry
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CORRESP 1 filename1.htm CORRESP www.netapp.com 408 822 6000 Tel 3060 Olsen Drive San Jose, CA 95128 United States February 2, 2023 Via EDGAR United States Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549-3628 Attn: Robert Littlepage, Accounting Branch Chief Inessa Kessman, Senior Staff Accountant Re: NetApp, Inc. Form 10-K for the Fiscal Year Ended April 29, 2022 Filed June 16, 2022 Form 10-Q for the Quarterly Period Ended October 28, 2022 Filed December 1, 2022 File No. 000-27130 Ladies and Gentlemen: NetApp, Inc. (the “Company”) submits this letter to you in response to your letter of January 23, 2023, which sets forth a comment of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the above-referenced filings. For your convenience, we have recited the Staff’s comment in italicized, bold type and have followed the comment with our response in regular, un-bold type. Form 10-Q for the quarterly period ended October 28, 2022 14. Segment, Geographic, and Significant Customer Information, page 22 1. Please disclose revenues from external customers for each product and service or each group of similar products and services in accordance with ASC 280-10-50-40. We note disclosure on page 28 and 30 which refers to various product categories including portfolios that include all-flash, hybrid-flash, and object storage systems. Response The Company respectfully acknowledges the Staff’s comment and advises the Staff of the following. In connection with the preparation of our segment financial statement disclosures, we considered ASC-280-10-50-40, which requires disclosure of “revenues from external customers of each product and service or each group of similar products and services unless it is impracticable to do so.” As the guidance does not provide a definition of “similar,” we have relied on an analysis of the facts and circumstances in each of our segments to determine whether the respective products and services revenues in those segments should be combined. In connection with this analysis, we concluded that the revenue line items in our existing reportable segments disclosure reflect appropriate groupings for the purposes of ASC 280-10-50-40. In reaching this conclusion, we analyzed the criteria outlined in ASC 280-10-50-11, and determined that, for the product revenues grouped and services revenues grouped in each segment, the nature of the products or services, the nature of their production processes, the type and class of customers for each, and the methods used to distribute the products and provide the services were similar and therefore should be grouped. For example, all Hybrid Cloud segment products, including all-flash, hybrid-flash and object storage, are storage systems that are regularly sold to customers across the same industries, and are subject to similar manufacturing and research and development processes, sales efforts, and distribution methods. Based on our analysis, we concluded that our segment disclosures provide investors meaningful information about groups of similar products and services in accordance with ASC 280-10-50-40. * * * * * We hope that you will find the foregoing responsive to the Staff’s comments. If you have any further questions or comments, please direct those to me at (408) 822-4599 or mike.berry@netapp.com. Thank you for your assistance. Sincerely, /s/ Michael Berry Michael Berry Executive Vice President and Chief Financial Officer, NetApp, Inc. cc: Elizabeth O’Callahan, Executive Vice President, Chief Legal Officer, NetApp, Inc. Amy Meese, Vice President, Corporate Legal, NetApp, Inc. Bobby Parks, Vice President and Chief Accounting Officer, NetApp, Inc. Brian Baer, Deloitte & Touche LLP Page 2