SEC Comment Letter for T-Mobile US, Inc. (TMUS) (CIK 0001283699) (TMUS) — Jun 25, 2009
T-Mobile US, Inc. (TMUS) (CIK 0001283699)
Date: June 25, 2009 · CIK: 0001283699 · Accession: 0000000000-09-033745
AI Filing Summary & Sentiment
File numbers found in text: 001-33409
Referenced dates: June 4, 2009, May 21, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 June 25, 2009 J. Braxton Carter Executive Vice President and Chief Financial Officer MetroPCS Communications, Inc. 2250 Lakeside Boulevard Richardson, Texas 75082 RE: MetroPCS Communications, Inc. Form 10-K for the year ended December 31, 2008 Filed March 2, 2009 File No. 001-33409
Dear Mr. Carter: We have reviewed your supplemental respons e letter dated June 4, 2009 as well as the above referenced filing and have the following comme nt. We have asked you to provide us with supplemental information so we may better understa nd your disclosure. Please be as detailed as necessary in your explanation. After reviewing this informa tion, we may or may not raise additional comments. Form 10-K for the year ended December 31, 2008
Management’s Discussion and Analysis, pages 52-84 1. Refer to your response to prior comment 3 in our letter dated May 21, 2009. We note that you use the market approach to value FCC licen ses that are in areas which you do not have formalized build-out plans. Due to the limited market activity for FCC licenses and differences in the use of various licenses based on spectrum and lo cation, it appears that ascertaining a market value for such license s may be quite complex. Please help us understand your use of a market approach by providing the following information:
• the reasons why you use the market approach for licenses covering areas where you do not currently have a formalized build-out plan,
• the basis for your belief that you can arrive at a reasonable determination of fair value using the market appro ach, including a discussion of your assumptions,
• whether you have developed internal company estimates of cash flow projections for these licenses,
MetroPCS Communications, Inc. June 25, 2009 Page 2 • describe how you intend to use the li censes that do not have a formalized build-out plan,
• how you determined that the FCC Aucti on 66 values are comparable to your licenses, clarifying whether you utilized ini tial auction values or resale market values as of the date of your impairment test, and
• the carrying amount of FCC licenses th at are valued based on the market approach.
Please respond to these comments thr ough correspondence over EDGAR within 10 business days or tell us when you will provide us with a response. You may contact Claire DeLabar, Staff Accountant, at (202) 551-3349, or Terry French, Accounting Branch Chief, at (202) 551-3828 if you have questions regardi ng comments on the financial statements and related matters. You may contact Reid Hooper, Staff Attorney, at (202) 551-3359, or me, at (202) 551-3257 with any other questions. S i n c e r e l y , Celeste M. Murphy L e g a l B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
June 25, 2009 J. Braxton Carter Executive Vice President and Chief Financial Officer MetroPCS Communications, Inc. 2250 Lakeside Boulevard Richardson, Texas 75082
RE: MetroPCS Communications, Inc. Form 10-K for the year ended December 31, 2008
Filed March 2, 2009
File No. 001-33409
Dear Mr. Carter:
We have reviewed your supplemental respons e letter dated June 4, 2009 as well as the
above referenced filing and have the following comme nt. We have asked you to provide us with
supplemental information so we may better understa nd your disclosure. Please be as detailed as
necessary in your explanation. After reviewing this informa tion, we may or may not raise
additional comments. Form 10-K for the year ended December 31, 2008
Management’s Discussion and Analysis, pages 52-84
1. Refer to your response to prior comment 3 in our letter dated May 21, 2009. We note that
you use the market approach to value FCC licen ses that are in areas which you do not have
formalized build-out plans. Due to the limited market activity for FCC licenses and differences in the use of various licenses based on spectrum and lo cation, it appears that
ascertaining a market value for such license s may be quite complex. Please help us
understand your use of a market approach by providing the following information:
• the reasons why you use the market approach for licenses covering areas
where you do not currently have a formalized build-out plan,
• the basis for your belief that you can arrive at a reasonable determination of
fair value using the market appro ach, including a discussion of your
assumptions,
• whether you have developed internal company estimates of cash flow
projections for these licenses,
MetroPCS Communications, Inc.
June 25, 2009 Page 2
• describe how you intend to use the li censes that do not have a formalized
build-out plan,
• how you determined that the FCC Aucti on 66 values are comparable to your
licenses, clarifying whether you utilized ini tial auction values or resale market
values as of the date of your impairment test, and
• the carrying amount of FCC licenses th at are valued based on the market
approach.
Please respond to these comments thr ough correspondence over EDGAR within 10
business days or tell us when you will provide us with a response. You may contact Claire
DeLabar, Staff Accountant, at (202) 551-3349, or Terry French, Accounting Branch Chief, at
(202) 551-3828 if you have questions regardi ng comments on the financial statements and
related matters. You may contact Reid Hooper, Staff Attorney, at (202) 551-3359, or me, at
(202) 551-3257 with any other questions. S i n c e r e l y , Celeste M. Murphy L e g a l B r a n c h C h i e f