SEC Comment Letter for BLACKBERRY Ltd (BB) (CIK 0001070235) (BB) — Aug 31, 2010
BLACKBERRY Ltd (BB) (CIK 0001070235)
Date: Aug. 31, 2010 · CIK: 0001070235 · Accession: 0000000000-10-050448
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-29898
Referenced dates: August 9, 2010, July 26, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D .C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 August 31, 2010 VIA INTERNATIONAL MAIL AND FAX (519)-885-0848 Mr. Brian Bidulka Chief Financial Officer Research in Motion Limited 295 Phillip Street Waterloo, Ontario Canada, N2L 3W8
RE: Research in Motion Limited Form 40-F for the fi scal y ear ended February 27, 2010 , as Amended Filed April 2, 2010 File No. 000-29898
Dear Mr. Bidulka :
We have reviewed your response letter dated August 9, 2010 and your filings and have the following comments. Please provide us with the requested inform ation so we may better understand your disclosure.
Please respond to this letter within ten business 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 y our 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 40 -F for the Year Ended February 27, 2010 , as Amended
Exhibit 1.2 Audited Consolidated Financial Statements 4. Cash, Cash Equivalents and Investments, page 17 5. Fair Value Measurements, page 19
1. We note your response to comment one from our letter dated July 26, 2010. It remains unclear to us how investment grade securities, such as government -sponsored enterprise notes, non -U.S. treasury bills and notes, and most recently, corporate bonds, may b e deemed cash equivalents that are “ readily convertible to known amounts of cash.” Please
Mr. Brian Bidulka Research in Motion Limited July 26, 2010 Page 2
explain to us in greater detail why you believe that you have the ability to liquidate these investments. More specifically, t ell us the nature of the liquid market s that you could access to exchange these investments for cash and the manner of liquidation . Tell us how quickl y the trades or liquidations have been or would be settled in cash. Are you required to wait until maturity to receive cash for any of th e aforementioned investments? If sold prior to the maturity date, would there be an y loss in the principal or would they sell at par value ? Additionally, could these investments lose value if the credit rating of the issuer is downgraded prior to maturity?
* * * *
Please respond to these comments through correspondence over EDGAR within 10 business days or tell us when y ou will provide us with a response. You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or Ivette Leon, Assistant Chief Accountant at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Pleas e contact me at (202) 551 -3810 with any other questions.
Sincerely,
Larry Spirgel
Assistant Director
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D .C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
August 31, 2010
VIA INTERNATIONAL MAIL AND FAX (519)-885-0848
Mr. Brian Bidulka
Chief Financial Officer
Research in Motion Limited
295 Phillip Street
Waterloo, Ontario
Canada, N2L 3W8
RE: Research in Motion Limited
Form 40-F for the fi scal y ear ended February 27, 2010 , as Amended
Filed April 2, 2010
File No. 000-29898
Dear Mr. Bidulka :
We have reviewed your response letter dated August 9, 2010 and your filings and have
the following comments. Please provide us with the requested inform ation so we may better
understand your disclosure.
Please respond to this letter within ten business 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 y our 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 40 -F for the Year Ended February 27, 2010 , as Amended
Exhibit 1.2
Audited Consolidated Financial Statements
4. Cash, Cash Equivalents and Investments, page 17
5. Fair Value Measurements, page 19
1. We note your response to comment one from our letter dated July 26, 2010. It remains
unclear to us how investment grade securities, such as government -sponsored enterprise
notes, non -U.S. treasury bills and notes, and most recently, corporate bonds, may b e
deemed cash equivalents that are “ readily convertible to known amounts of cash.” Please
Mr. Brian Bidulka
Research in Motion Limited
July 26, 2010
Page 2
explain to us in greater detail why you believe that you have the ability to liquidate these
investments. More specifically, t ell us the nature of the liquid market s that you could
access to exchange these investments for cash and the manner of liquidation . Tell us how
quickl y the trades or liquidations have been or would be settled in cash. Are you required
to wait until maturity to receive cash for any of th e aforementioned investments? If sold
prior to the maturity date, would there be an y loss in the principal or would they sell at
par value ? Additionally, could these investments lose value if the credit rating of the
issuer is downgraded prior to maturity?
* * * *
Please respond to these comments through correspondence over EDGAR within 10
business days or tell us when y ou will provide us with a response. You may contact Kathryn
Jacobson, Senior Staff Accountant, at (202) 551-3365 or Ivette Leon, Assistant Chief Accountant
at (202) 551 -3351 if you have questions regarding comments on the financial statements and
related matters. Pleas e contact me at (202) 551 -3810 with any other questions.
Sincerely,
Larry Spirgel
Assistant Director