SEC Comment Letter for Stride, Inc. (LRN) (CIK 0001157408) (LRN) — Feb 25, 2015
Stride, Inc. (LRN) (CIK 0001157408)
Date: Feb. 25, 2015 · CIK: 0001157408 · Accession: 0000000000-15-011884
AI Filing Summary & Sentiment
Referenced dates: January 23, 2015
Letter
February 25 , 2015 Via E -mail Mr. James Rhyu Chief Financial Officer K12, Inc. 2300 Corporate Park Drive Herndon, VA 20171
Re: K12, Inc. Form 10 -K for the Fiscal Year Ended June 30, 2014 Filed August 15, 2014 Response dated February 6, 2015 File No. 001 -33883
Dear Mr. Rhyu :
We have reviewed your response letter and have the following comment. As noted in our letter dated January 23, 2015, we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. 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 applies to your f acts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, we may have additional comments.
Form 10 -K for the Fiscal Y ear ended June 30, 2014
Comparison of Years Ended June 30, 2014 and 2013, page 74
1. We note that in response to comment 3 , you attribute the overall decline in enrollment growth rate in 2014 to operational issues in processing applications. In your future MD&A discussions, please describe in sufficient detail an y issues impacting the growth in enrollment similar to the events and circumstances explained in your response to comment 3. Please note in this disclosure any issues, such as the imposition of an
Mr. James Rhyu K12, Inc. February 25 , 2015 Page 2
enrollment cap in Tennessee or the transition of certain s chools (i.e., Colorado, Kansas, and Hawaii) from managed to non -managed programs that may impact the future trend in enrollment growth, revenues and operating income.
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 the comment on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage, for
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February 25 , 2015 Via E -mail Mr. James Rhyu Chief Financial Officer K12, Inc. 2300 Corporate Park Drive Herndon, VA 20171 Re: K12, Inc. Form 10 -K for the Fiscal Year Ended June 30, 2014 Filed August 15, 2014 Response dated February 6, 2015 File No. 001 -33883 Dear Mr. Rhyu : We have reviewed your response letter and have the following comment. As noted in our letter dated January 23, 2015, we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. 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 applies to your f acts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10 -K for the Fiscal Y ear ended June 30, 2014 Comparison of Years Ended June 30, 2014 and 2013, page 74 1. We note that in response to comment 3 , you attribute the overall decline in enrollment growth rate in 2014 to operational issues in processing applications. In your future MD&A discussions, please describe in sufficient detail an y issues impacting the growth in enrollment similar to the events and circumstances explained in your response to comment 3. Please note in this disclosure any issues, such as the imposition of an Mr. James Rhyu K12, Inc. February 25 , 2015 Page 2 enrollment cap in Tennessee or the transition of certain s chools (i.e., Colorado, Kansas, and Hawaii) from managed to non -managed programs that may impact the future trend in enrollment growth, revenues and operating income. 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 the comment on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spirgel Assistant Director