SEC Comment Letter for COMMVAULT SYSTEMS INC (CVLT) (CIK 0001169561) (CVLT) — Nov 21, 2017
COMMVAULT SYSTEMS INC (CVLT) (CIK 0001169561)
Date: Nov. 21, 2017 · CIK: 0001169561 · Accession: 0000000000-17-041052
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4561 November 21, 2017 Brian Carolan Vice President, Chief Financial Officer Commvault Systems, Inc. 1 Commvault Way Tinton Falls, NJ 07724
Re: Commvault Systems, Inc. Form 10 -K for the Fiscal Year Ended March 31, 2017 Filed May 5, 2017 Form 10 -Q for the Quarter Ended June 30, 2017 Filed July 26, 2017 Response dated October 27, 2017 File No. 001 -33026
Dear Mr. Carolan :
We have reviewed your October 27, 2017 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this 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 our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional com ments. Unless we note otherwise, our references to prior comments are to comments in our October 19, 2017 letter.
Form 10 -Q for the Quarterly Period Ended June 30, 2017
Note 3. Revenue, page 9
1. We have reviewed your response to prior comment 4. We note th e minimum and maximum amounts; h owever, it is unclear to us how you considered transactions within this range. Please provide us with more details of your analysis. In this regard, please tell us whether a significant number of transactions fel l within a smaller portion of this range. Reference ASC 606 -10-32-34(c).
Brian Carolan Commvault Systems, Inc. November 21, 2017 Page 2
You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 if you have questions regarding comments on the financial statements and related matters. Please contact me at (20 2) 551-3499 with any other questions.
Sincerely,
/s/ Kathleen Collins
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Mail Stop 4561 November 21, 2017 Brian Carolan Vice President, Chief Financial Officer Commvault Systems, Inc. 1 Commvault Way Tinton Falls, NJ 07724 Re: Commvault Systems, Inc. Form 10 -K for the Fiscal Year Ended March 31, 2017 Filed May 5, 2017 Form 10 -Q for the Quarter Ended June 30, 2017 Filed July 26, 2017 Response dated October 27, 2017 File No. 001 -33026 Dear Mr. Carolan : We have reviewed your October 27, 2017 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional com ments. Unless we note otherwise, our references to prior comments are to comments in our October 19, 2017 letter. Form 10 -Q for the Quarterly Period Ended June 30, 2017 Note 3. Revenue, page 9 1. We have reviewed your response to prior comment 4. We note th e minimum and maximum amounts; h owever, it is unclear to us how you considered transactions within this range. Please provide us with more details of your analysis. In this regard, please tell us whether a significant number of transactions fel l within a smaller portion of this range. Reference ASC 606 -10-32-34(c). Brian Carolan Commvault Systems, Inc. November 21, 2017 Page 2 You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 if you have questions regarding comments on the financial statements and related matters. Please contact me at (20 2) 551-3499 with any other questions. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services