SEC Comment Letter for ACCURAY INC (ARAY) (CIK 0001138723) (ARAY) — May 4, 2015
ACCURAY INC (ARAY) (CIK 0001138723)
Date: May 4, 2015 · CIK: 0001138723 · Accession: 0000000000-15-024366
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33301
Referenced dates: April 10, 2015
Letter
May 1, 2015 Via E -mail Gregory E. Lichtwardt Executive Vice President and Chief Financial Officer Accuray Incorporated 1310 Chesapeake Terrace Sunnyvale, California 94089
Re: Accuray Incorporated Form 10 -K for the Fiscal Year E nded June 30, 2014 Filed August 29, 2014 File No. 001-33301
Dear Mr. Lichtwardt :
We have completed our review of your filing. In connection with future filings that require you to address Regulation S -K Item 101, we encourage you to consider (1) whether, given your facts and circumstances, Item 101(c)(1)(i) requires revenue history dis closure in addition to the information required by the accounting standard that you cite in your letter dated April 10, 2015, and (2) whether the data that you use to prepare the guidance that you mention in the last sentence of response 4 in your letter d ated April 10, 2015 provides the information necessary to disclose the portion of your backlog not reasonably expected to be filled within the then current year as required by Item 101(c)(1)(viii).
We remind you that our comments or changes to disclosur e in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applica ble rules require.
Sincerely,
/s/ Russell Mancuso
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May 1, 2015
Via E -mail
Gregory E. Lichtwardt
Executive Vice President and Chief Financial Officer
Accuray Incorporated
1310 Chesapeake Terrace
Sunnyvale, California 94089
Re: Accuray Incorporated
Form 10 -K for the Fiscal Year E nded June 30, 2014
Filed August 29, 2014
File No. 001-33301
Dear Mr. Lichtwardt :
We have completed our review of your filing. In connection with future filings that
require you to address Regulation S -K Item 101, we encourage you to consider (1) whether,
given your facts and circumstances, Item 101(c)(1)(i) requires revenue history dis closure in
addition to the information required by the accounting standard that you cite in your letter dated
April 10, 2015, and (2) whether the data that you use to prepare the guidance that you mention in
the last sentence of response 4 in your letter d ated April 10, 2015 provides the information
necessary to disclose the portion of your backlog not reasonably expected to be filled within the
then current year as required by Item 101(c)(1)(viii).
We remind you that our comments or changes to disclosur e in response to our comments
do not foreclose the Commission from taking any action with respect to the company or 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. We urge all
persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be
certain that the filing includes the information the Securities Exchange Act of 1934 and all
applica ble rules require.
Sincerely,
/s/ Russell Mancuso
Russell Mancuso
Branch Chief
cc (via e -mail) : Katharine A. Martin,
Wilson Sonsini Goodrich & Rosati, P.C.