SEC Comment Letter for T-Mobile US, Inc. (TMUS) (CIK 0001283699) (TMUS) — May 15, 2015
T-Mobile US, Inc. (TMUS) (CIK 0001283699)
Date: May 15, 2015 · CIK: 0001283699 · Accession: 0000000000-15-026578
AI Filing Summary & Sentiment
File numbers found in text: 001-33409
Letter
May 15 , 2015 Mr. John J. Legere President and Chief Executive Officer T-Mobile US, Inc. 12920 SE 38th Street Bellevue, WA 98006 -1350
Re: T-Mobile US, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Response Dated May 13, 2015 Form 10 -Q for Fiscal Quarter Ended March 31, 2015 File No. 001-33409
Dear Mr. Legere :
We have reviewed your May 13, 2015 response to our comment letter and have the following comments. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. In some of our comments, we may ask you to provide us with information so we m ay better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circ umstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments. .
Form 10 -K for Fiscal Year Ended December 31, 2014
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Operating Expenses, pages 27 and 29
1. We note your response to comment 2. Please tell us why customer care costs, including customer support and billing, are not considered costs of services. In addition, tell us the amount of such costs for 2014, 2013 and 2012.
John J. Legere T-Mobile US, Inc. May 15 , 2015 Page 2
Form 10 -Q for Fiscal Quarter Ended March 31, 2015
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Three Months Ended March 31, 2015 Compared to Three Months Ended March 31, 2014 Revenues, Branded Postpaid Revenues, page 21
2. We note your response to comment 4 and your proposed disclosure. Please disclose your multiple -element arrangements including the Free 10G Starter Stash and Personal Data Stash deliverables pursuant to ASC 605 -25-50-2 and Rule 10 -01(a)(5) , or tell us why such disclosure is not necessary.
You may contact Robert Shapiro, Staff Accountant , at (202) 551 -3273 or Dean Suehiro, Senior Staff Accountant, at (202) 551 -3384 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer, Attorney -Advisor, at (202) 551-3415, Celeste Murphy, Lega l Branch Chief, at (202) 551 -3257 or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage, for
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May 15 , 2015 Mr. John J. Legere President and Chief Executive Officer T-Mobile US, Inc. 12920 SE 38th Street Bellevue, WA 98006 -1350 Re: T-Mobile US, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Response Dated May 13, 2015 Form 10 -Q for Fiscal Quarter Ended March 31, 2015 File No. 001-33409 Dear Mr. Legere : We have reviewed your May 13, 2015 response to our comment letter and have the following comments. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. In some of our comments, we may ask you to provide us with information so we m ay better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circ umstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. . Form 10 -K for Fiscal Year Ended December 31, 2014 Management’s Discussion and Analysis of Financial Condition and Results of Operations Operating Expenses, pages 27 and 29 1. We note your response to comment 2. Please tell us why customer care costs, including customer support and billing, are not considered costs of services. In addition, tell us the amount of such costs for 2014, 2013 and 2012. John J. Legere T-Mobile US, Inc. May 15 , 2015 Page 2 Form 10 -Q for Fiscal Quarter Ended March 31, 2015 Management’s Discussion and Analysis of Financial Condition and Results of Operations Three Months Ended March 31, 2015 Compared to Three Months Ended March 31, 2014 Revenues, Branded Postpaid Revenues, page 21 2. We note your response to comment 4 and your proposed disclosure. Please disclose your multiple -element arrangements including the Free 10G Starter Stash and Personal Data Stash deliverables pursuant to ASC 605 -25-50-2 and Rule 10 -01(a)(5) , or tell us why such disclosure is not necessary. You may contact Robert Shapiro, Staff Accountant , at (202) 551 -3273 or Dean Suehiro, Senior Staff Accountant, at (202) 551 -3384 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer, Attorney -Advisor, at (202) 551-3415, Celeste Murphy, Lega l Branch Chief, at (202) 551 -3257 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spirgel Assistant Director