SEC Comment Letter for Strategy (MSTR) — Jul 10, 2014
Strategy Inc
Date: July 10, 2014 · CIK: 0001050446 · Accession: 0000000000-14-034776
AI Filing Summary & Sentiment
Referenced dates: June 20, 2014, June 26, 2014
Letter
July 10 , 2014 Via E -mail Douglas K. Thede Senior Executive Vice President & Chief Financial Officer MicroStrategy Incorporated 1850 Towers Crescent Plaza Tysons Corner, Virginia 22182
Re: MicroStrategy Incorporated Form 10-K for the Fiscal Year Ended December 31, 2013 Filed February 12, 2014 File No. 000 -24435
Dear Mr. Thede :
We have reviewed your letter dated June 26, 2014 in connection with the above - referenced filing an d 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 letter within ten business days by amending your filing, by providing the requested informatio n, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated June 20, 2014 .
Consolidate d Statements of Operations, page 73
1. We note your response to prior comment 1. As subscription services are service contracts, classification as service revenue would be appropriate in accordance with Rule 5-03 (b)(1) of Regulation S -X. Please confirm th at if subscription revenue becomes greater than 10% of total revenue it will be properly classified as service revenue. Alternatively, you may disclose subscription revenue on its own line.
Douglas K. Thede MicroStrategy Incorporated July 10 , 2014 Page 2
You may contact Eiko Yaoita Pyles, Staff Accountant , at (20 2) 551 -3587, or Christine Davis Assistant Chief Accountant, at (202) 551 -3408, if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3406.
Sincerely,
/s/ Patrick Gilmore
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July 10 , 2014 Via E -mail Douglas K. Thede Senior Executive Vice President & Chief Financial Officer MicroStrategy Incorporated 1850 Towers Crescent Plaza Tysons Corner, Virginia 22182 Re: MicroStrategy Incorporated Form 10-K for the Fiscal Year Ended December 31, 2013 Filed February 12, 2014 File No. 000 -24435 Dear Mr. Thede : We have reviewed your letter dated June 26, 2014 in connection with the above - referenced filing an d 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 letter within ten business days by amending your filing, by providing the requested informatio n, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated June 20, 2014 . Consolidate d Statements of Operations, page 73 1. We note your response to prior comment 1. As subscription services are service contracts, classification as service revenue would be appropriate in accordance with Rule 5-03 (b)(1) of Regulation S -X. Please confirm th at if subscription revenue becomes greater than 10% of total revenue it will be properly classified as service revenue. Alternatively, you may disclose subscription revenue on its own line. Douglas K. Thede MicroStrategy Incorporated July 10 , 2014 Page 2 You may contact Eiko Yaoita Pyles, Staff Accountant , at (20 2) 551 -3587, or Christine Davis Assistant Chief Accountant, at (202) 551 -3408, if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3406. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief