SEC Comment Letter for NVIDIA CORP (NVDA) (CIK 0001045810) (NVDA) — Jun 6, 2014
NVIDIA CORP (NVDA) (CIK 0001045810)
Date: June 6, 2014 · CIK: 0001045810 · Accession: 0000000000-14-028989
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-23985
Letter
June 6 , 2013 Via Email Colette M. Kress Executive Vice President and Chief Financial Officer NVIDIA Corporation 2701 San Tomas Expressway Santa Clara, CA 95050
Re: NVIDIA Corporation Form 10 -K for the Year Ended January 26, 2014 Filed March 13, 2014 File No. 000-23985
Dear Ms. Kress : We have reviewed your filing an d have the following comments. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. 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 b usiness 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 January 2 6, 201 4
Note 16. Segment Information, page 95
1. We note on page 5 you refer to various product lines that make up your GPU and Tegra Processor businesses. Please revise future filings to provide the disclosures required by FASB ASC 280 -10-50-40.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
Colette M. Kress NVIDIA Corporation June 6, 2014 Page 2
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact 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
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June 6 , 2013 Via Email Colette M. Kress Executive Vice President and Chief Financial Officer NVIDIA Corporation 2701 San Tomas Expressway Santa Clara, CA 95050 Re: NVIDIA Corporation Form 10 -K for the Year Ended January 26, 2014 Filed March 13, 2014 File No. 000-23985 Dear Ms. Kress : We have reviewed your filing an d have the following comments. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. 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 b usiness 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 January 2 6, 201 4 Note 16. Segment Information, page 95 1. We note on page 5 you refer to various product lines that make up your GPU and Tegra Processor businesses. Please revise future filings to provide the disclosures required by FASB ASC 280 -10-50-40. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; Colette M. Kress NVIDIA Corporation June 6, 2014 Page 2 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact 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