SEC Comment Letter 0000000000-23-007462 to CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922) (CHKP)
CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922)
Date: July 12, 2023 · CIK: 0001015922 · Accession: 0000000000-23-007462
AI Filing Summary & Sentiment
File numbers found in text: 000-28584
Letter
United States securities and exchange commission logo July 12, 2023 Roei Golan Chief Financial Officer Check Point Software Technologies Ltd. 5 Shlomo Kaplan Street Tel Aviv 6789159 , Israel Re:Check Point Software Technologies Ltd. Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 27, 2023 File No. 000-28584 Dear Roei Golan: We have reviewed your June 21, 2023 response to our comment letter and have the following comment. In our comment, we 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 June 8, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Consolidated Financial Statements Notes to Consolidated Financial Statements Note 4 Cash and Cash Equivalents, Short-Term Bank Deposits and Marketable Securities, page F-28 1.Please provide a legal analysis of whether the Company meets the definition of “investment company” under Section 3(a) of the Investment Company Act of 1940 (the “1940 Act”). Please include in your analysis all relevant calculations under Section 3(a)(1)(C) on an unconsolidated basis, identifying each constituent part of the numerator(s) and denominator(s). Please also describe and discuss any other substantive determinations and/or characterizations of assets that are material to your calculations. Additionally, if the Company meets the definition of “investment company” under Section
FirstName LastNameRoei Golan Comapany NameCheck Point Software Technologies Ltd. July 12, 2023 Page 2 FirstName LastName Roei Golan Check Point Software Technologies Ltd. July 12, 2023 Page 2 3(a) of the 1940 Act but relies or intends to rely on an exclusion therefrom or a relevant exemption, please provide a legal analysis supporting such reliance. You may contact Laura Veator, Senior Staff Accountant, at (202)-551-3716 or Stephen Krikorian, Accounting Branch Chief, at (202)-551-3488 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
July 12, 2023
Roei Golan
Chief Financial Officer
Check Point Software Technologies Ltd.
5 Shlomo Kaplan Street
Tel Aviv 6789159 , Israel
Re:Check Point Software Technologies Ltd.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 27, 2023
File No. 000-28584
Dear Roei Golan:
We have reviewed your June 21, 2023 response to our comment letter and have the
following comment. In our comment, we 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
June 8, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 4 Cash and Cash Equivalents, Short-Term Bank Deposits and Marketable Securities, page
F-28
1.Please provide a legal analysis of whether the Company meets the definition of
“investment company” under Section 3(a) of the Investment Company Act of 1940 (the
“1940 Act”). Please include in your analysis all relevant calculations under Section
3(a)(1)(C) on an unconsolidated basis, identifying each constituent part of the
numerator(s) and denominator(s). Please also describe and discuss any other substantive
determinations and/or characterizations of assets that are material to your calculations.
Additionally, if the Company meets the definition of “investment company” under Section
FirstName LastNameRoei Golan
Comapany NameCheck Point Software Technologies Ltd.
July 12, 2023 Page 2
FirstName LastName
Roei Golan
Check Point Software Technologies Ltd.
July 12, 2023
Page 2
3(a) of the 1940 Act but relies or intends to rely on an exclusion therefrom or a relevant
exemption, please provide a legal analysis supporting such reliance.
You may contact Laura Veator, Senior Staff Accountant, at (202)-551-3716 or Stephen
Krikorian, Accounting Branch Chief, at (202)-551-3488 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology