SEC Comment Letter for NVIDIA CORP (NVDA) (CIK 0001045810) (NVDA) — Jul 31, 2013
NVIDIA CORP (NVDA) (CIK 0001045810)
Date: July 31, 2013 · CIK: 0001045810 · Accession: 0000000000-13-041888
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-23985
Referenced dates: July 17, 2013
Letter
July 31 , 2013 Via Email Karen Burns Vice President and Interim Chief Financial Officer NVIDIA Corporation 2701 San Tomas Expressway Santa Clara, CA 95050
Re: NVIDIA Corporation Form 10 -K for the Year Ended January 27, 2013 Filed March 12, 2013 File No. 000-23985
Dear Ms. Burns :
We have reviewed your letter dated July 17, 2013 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 this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Year Ended Ja nuary 27, 2013
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 38
Inventories, page 41
1. We note your response to prior comment 1. Please address the following:
Tell us how your use and disclosure of i ncreases and decreases in an inventory “reserve” is consistent with the guidance in SAB Topic 5BB.
Alternatively, revise the proposed disclosure to remove the references to an inventory reserve and to instead discuss the inventory write -downs taken in ea ch reported period. Revise the discussion in the Critical Accounting Policies and Estimates
Karen Burns NVIDIA Corporation July 31, 2013 Page 2
section of MD&A to provide a robust discussion of the factors that resulted in the write -downs in each period and to clearly discuss the critical estimates and assumptions you make in determining obsolete and excess inventory amounts, as well as the estimated market value of your inventory.
To enhance the investor’s understanding of the reliability of your estimates, revise the section to disclose the amounts of i nventory write -downs recorded in each reported period as well as the amounts by which your gross margins were favorably impacted by the sale of previously written -down inventory in those periods.
Provide us a copy of your proposed disclosure.
You may con tact Eric Atallah, Staff Accountant at (202) 551 -3663 or me at (202) 551 - 3643 if you have questions regarding these comments. In this regard, do not hesitate to contact Martin James, Senior Assistant Chief Accountant at (202) 551 -3671 .
Sincerely,
/s/ Kevin L. Vaughn
Show Raw Text
July 31 , 2013 Via Email Karen Burns Vice President and Interim Chief Financial Officer NVIDIA Corporation 2701 San Tomas Expressway Santa Clara, CA 95050 Re: NVIDIA Corporation Form 10 -K for the Year Ended January 27, 2013 Filed March 12, 2013 File No. 000-23985 Dear Ms. Burns : We have reviewed your letter dated July 17, 2013 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 this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10 -K for the Year Ended Ja nuary 27, 2013 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 38 Inventories, page 41 1. We note your response to prior comment 1. Please address the following: Tell us how your use and disclosure of i ncreases and decreases in an inventory “reserve” is consistent with the guidance in SAB Topic 5BB. Alternatively, revise the proposed disclosure to remove the references to an inventory reserve and to instead discuss the inventory write -downs taken in ea ch reported period. Revise the discussion in the Critical Accounting Policies and Estimates Karen Burns NVIDIA Corporation July 31, 2013 Page 2 section of MD&A to provide a robust discussion of the factors that resulted in the write -downs in each period and to clearly discuss the critical estimates and assumptions you make in determining obsolete and excess inventory amounts, as well as the estimated market value of your inventory. To enhance the investor’s understanding of the reliability of your estimates, revise the section to disclose the amounts of i nventory write -downs recorded in each reported period as well as the amounts by which your gross margins were favorably impacted by the sale of previously written -down inventory in those periods. Provide us a copy of your proposed disclosure. You may con tact Eric Atallah, Staff Accountant at (202) 551 -3663 or me at (202) 551 - 3643 if you have questions regarding these comments. In this regard, do not hesitate to contact Martin James, Senior Assistant Chief Accountant at (202) 551 -3671 . Sincerely, /s/ Kevin L. Vaughn Kevin L. Vaughn Accounting Branch Chief