SEC Comment Letter for Strategy (MSTR) — Jun 27, 2011
Strategy Inc
Date: June 27, 2011 · CIK: 0001050446 · Accession: 0000000000-11-038947
AI Filing Summary & Sentiment
File numbers found in text: 000-24435
Referenced dates: April 20, 2011
Letter
June 27, 2011 Via Facsimile Douglas K. Thede Executive Vice President, Finance and Chief Financial Officer Microstrategy, Inc. 1850 Towers Crescent Plaza Vienna, VA 22182 Re: Microstrategy, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 18, 2011 File No. 000-24435
Dear Mr. Thede: We have reviewed your letter dated Ma y 25, 2011 in connection with the above- referenced filing 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 amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they refe r to our letter dated April 20, 2011. Notes to Consolidated Financial Statements
(2) Summary of Significant Accounting Policies
(h) Revenue Recognition, page 66
1. We have reviewed your response to prior comm ent 4. We reissue part of our previous comment to tell us your pri ce range of renewal rates that represents vendor-specific objective evidence (VSOE) of fair value for post-contr act support, including your minimum substantive VSOE rate.
Mr. Douglas Thede Microstrategy, Inc. June 27, 2011 Page 2 You may contact David Edgar, Staff Accountant, at (202) 551-3459 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3406 with any other questions. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief
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June 27, 2011 Via Facsimile Douglas K. Thede Executive Vice President, Finance and Chief Financial Officer Microstrategy, Inc. 1850 Towers Crescent Plaza Vienna, VA 22182 Re: Microstrategy, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 18, 2011 File No. 000-24435 Dear Mr. Thede: We have reviewed your letter dated Ma y 25, 2011 in connection with the above- referenced filing 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 amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they refe r to our letter dated April 20, 2011. Notes to Consolidated Financial Statements (2) Summary of Significant Accounting Policies (h) Revenue Recognition, page 66 1. We have reviewed your response to prior comm ent 4. We reissue part of our previous comment to tell us your pri ce range of renewal rates that represents vendor-specific objective evidence (VSOE) of fair value for post-contr act support, including your minimum substantive VSOE rate. Mr. Douglas Thede Microstrategy, Inc. June 27, 2011 Page 2 You may contact David Edgar, Staff Accountant, at (202) 551-3459 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3406 with any other questions. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief