SEC Comment Letter for BLACKBERRY Ltd (BB) (CIK 0001070235) (BB) — Jul 17, 2014
BLACKBERRY Ltd (BB) (CIK 0001070235)
Date: July 17, 2014 · CIK: 0001070235 · Accession: 0000000000-14-036205
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-29898
Letter
July 17, 2014 Via Email Mr. James Yersh Chief Financial Officer BlackBerry Limited 2200 University Avenue East Waterloo, Ontario Canada, N2 K 0A7
Re: BlackBerry Limited Form 40-F for the F iscal Year E nded March 1, 201 4 Filed March 28, 2014 Response dated July 11, 2014 File No. 000-29898
Dear Mr. Yersh :
We have reviewed your response letter and have the following comment . Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
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 comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to the comment, we may have additional comments.
Exhibit 1.2
Financial Statements
Consolidat ed Statements of Operations
1. We note your response to comment 1. If material, please separately present inventory write -downs and supply commitment charges on the face of your consolidated statements of operations. This presentation provides more transpa rency to investors than your proposed presentation.
You may contact Dean Suehiro , Senior Staff Accountant , at 202-551-3384 or Joseph M. Kempf , Senior Staff Accountant, a t 202-551-3352 if you have questions regarding comments on
Mr. James Yersh BlackBerry Limited July 17, 2014 Page 2
the financial statements and related matters. Please contact Paul Fischer , Attorney -Advisor, at 202-551-3415 or me at 202-551-3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage, for
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July 17, 2014 Via Email Mr. James Yersh Chief Financial Officer BlackBerry Limited 2200 University Avenue East Waterloo, Ontario Canada, N2 K 0A7 Re: BlackBerry Limited Form 40-F for the F iscal Year E nded March 1, 201 4 Filed March 28, 2014 Response dated July 11, 2014 File No. 000-29898 Dear Mr. Yersh : We have reviewed your response letter and have the following comment . Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. 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 comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to the comment, we may have additional comments. Exhibit 1.2 Financial Statements Consolidat ed Statements of Operations 1. We note your response to comment 1. If material, please separately present inventory write -downs and supply commitment charges on the face of your consolidated statements of operations. This presentation provides more transpa rency to investors than your proposed presentation. You may contact Dean Suehiro , Senior Staff Accountant , at 202-551-3384 or Joseph M. Kempf , Senior Staff Accountant, a t 202-551-3352 if you have questions regarding comments on Mr. James Yersh BlackBerry Limited July 17, 2014 Page 2 the financial statements and related matters. Please contact Paul Fischer , Attorney -Advisor, at 202-551-3415 or me at 202-551-3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spirgel Assistant Director