SEC Comment Letter for Strategy (MSTR) — Jul 3, 2013
Strategy Inc
Date: July 3, 2013 · CIK: 0001050446 · Accession: 0000000000-13-036377
AI Filing Summary & Sentiment
Letter
July 3, 2013 Via E -mail Douglas K. Thede Senior Executive Vice President & Chief Financial Officer MicroStrategy Incorporated 1850 Towers Crescent Plaza Tysons Corner, VA 22182
Re: MicroStrategy Incorporated Form 10-K for the Fiscal Year Ended December 31, 2012 Filed February 13, 2013 Form 8 -K filed March 15, 2013 File No. 000 -24435
Dear Mr. Thede :
We have completed our review of your filings. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Patrick Gilmore
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July 3, 2013 Via E -mail Douglas K. Thede Senior Executive Vice President & Chief Financial Officer MicroStrategy Incorporated 1850 Towers Crescent Plaza Tysons Corner, VA 22182 Re: MicroStrategy Incorporated Form 10-K for the Fiscal Year Ended December 31, 2012 Filed February 13, 2013 Form 8 -K filed March 15, 2013 File No. 000 -24435 Dear Mr. Thede : We have completed our review of your filings. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief