SEC Comment Letter for BLACKBERRY Ltd (BB) (CIK 0001070235) (BB) — Jun 3, 2016
BLACKBERRY Ltd (BB) (CIK 0001070235)
Date: June 3, 2016 · CIK: 0001070235 · Accession: 0000000000-16-079091
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-29898
Letter
June 2 , 2016 Via Email Mr. James Yersh Chief Financial Officer BlackBerry Limited 2200 University Ave East Waterloo, Ontario , Canada N2K0A7
Re: BlackBerry Limited Form 40-F for the Fiscal Y ear Ended February 29, 2016 Filed April 1, 2016 File No. 000-29898
Dear Mr. Yersh :
We have reviewed your filing and have the following comment . In our comment, we are asking you to provide us with information so we may better understand your disclosure.
Please respond to th e 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 o ur comment appl ies to your facts and circumstances , plea se tell us why in your response.
After reviewing your response to the comment , we may have additional comments.
Exhibit 1.2 . Audited Consolidated Financial Statements
Note 1. BlackBerry Limited and Summary of Significant Accounting Policies and Critical Accounting Estimates
Revenue Recognition
Software and Services, page 6
1. For your outbound patent licensing agreements, it appears that you are recognizing the related revenues upon the signing of such agreements. Please tell us why revenues are not recognized over the terms of the outbound patent licensing agreements.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the fi ling includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are
Mr. James Yersh BlackBerry Limited June 2, 201 6 Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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.
You may contact Dean Suehiro, Senior Staff Accountant, at (202) 551 -3384 or Robert Littlepage, Accountant Branch Chief, at (202) 551 -3361 if you have questions regarding comments on the financial statements and related matters. Please contact Greg Dundas, Attorney -Advisor at (202) 551 -3436 or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Terry French for
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June 2 , 2016 Via Email Mr. James Yersh Chief Financial Officer BlackBerry Limited 2200 University Ave East Waterloo, Ontario , Canada N2K0A7 Re: BlackBerry Limited Form 40-F for the Fiscal Y ear Ended February 29, 2016 Filed April 1, 2016 File No. 000-29898 Dear Mr. Yersh : We have reviewed your filing and have the following comment . In our comment, we are asking you to provide us with information so we may better understand your disclosure. Please respond to th e 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 o ur comment appl ies to your facts and circumstances , plea se tell us why in your response. After reviewing your response to the comment , we may have additional comments. Exhibit 1.2 . Audited Consolidated Financial Statements Note 1. BlackBerry Limited and Summary of Significant Accounting Policies and Critical Accounting Estimates Revenue Recognition Software and Services, page 6 1. For your outbound patent licensing agreements, it appears that you are recognizing the related revenues upon the signing of such agreements. Please tell us why revenues are not recognized over the terms of the outbound patent licensing agreements. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the fi ling includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are Mr. James Yersh BlackBerry Limited June 2, 201 6 Page 2 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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. You may contact Dean Suehiro, Senior Staff Accountant, at (202) 551 -3384 or Robert Littlepage, Accountant Branch Chief, at (202) 551 -3361 if you have questions regarding comments on the financial statements and related matters. Please contact Greg Dundas, Attorney -Advisor at (202) 551 -3436 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Terry French for Larry Spirgel Assistant Director AD Office 11 – Telecommunication s