SEC Comment Letter for AMDOCS (DOX) — Feb 11, 2020
AMDOCS LTD
Date: Feb. 11, 2020 · CIK: 0001062579 · Accession: 0000000000-20-001288
AI Filing Summary & Sentiment
File numbers found in text: 001-14840
Letter
February 11, 2020 Shuky Sheffer President and Chief Executive Officer Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, Missouri 63017 Re:Amdocs Limited Form 20-F for the Fiscal Year Ended September 30, 2019 Filed December 16, 2019 File No. 001-14840 Dear Mr. Sheffer: We have reviewed your filing and 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 comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Fiscal Year Ended September 30, 2019 Item 5. Operating and Financial Review and Prospects Liquidity and Capital Resources, page 37 1.We note your normalized free cash flow measure excludes charges that required cash settlement. Such charges cannot be excluded from non-GAAP liquidity measures per Item 10(e)(1)(ii)(A) of Regulation S-K. Please remove the measure or explain how it complies.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameShuky Sheffer Comapany NameAmdocs Limited February 11, 2020 Page 2 FirstName LastName Shuky Sheffer Amdocs Limited February 11, 2020 Page 2 You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Melissa Kindelan, Senior Staff Accountant at 202-551-3564 if you have questions. Sincerely, Division of Corporation Finance Office of Technology
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February 11, 2020
Shuky Sheffer
President and Chief Executive Officer
Amdocs Limited
1390 Timberlake Manor Parkway
Chesterfield, Missouri 63017
Re:Amdocs Limited
Form 20-F for the Fiscal Year Ended September 30, 2019
Filed December 16, 2019
File No. 001-14840
Dear Mr. Sheffer:
We have reviewed your filing and 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 comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended September 30, 2019
Item 5. Operating and Financial Review and Prospects
Liquidity and Capital Resources, page 37
1.We note your normalized free cash flow measure excludes charges that required cash
settlement. Such charges cannot be excluded from non-GAAP liquidity measures per Item
10(e)(1)(ii)(A) of Regulation S-K. Please remove the measure or explain how it complies.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameShuky Sheffer
Comapany NameAmdocs Limited
February 11, 2020 Page 2
FirstName LastName
Shuky Sheffer
Amdocs Limited
February 11, 2020
Page 2
You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Melissa
Kindelan, Senior Staff Accountant at 202-551-3564 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology