SEC Comment Letter for GTT Communications, Inc. (CIK 0001315255) — Apr 22, 2020
GTT Communications, Inc. (CIK 0001315255)
Date: April 22, 2020 · CIK: 0001315255 · Accession: 0000000000-20-003438
AI Filing Summary & Sentiment
File numbers found in text: 001-35965
Letter
April 21, 2020 Steven Berns Chief Financial Officer GTT Communications, Inc. 7900 Tysons One Place Suite 1450 McLean, VA 22102 Re:GTT Communications, Inc. Form 10-K for the Year Ended December 31,2019 Filed March 2, 2020 File No. 001-35965 Dear Mr. Berns: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31,2019 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Measures, page 31 1.We note that you present Adjusted Free Cash Flow and Adjusted Unlevered Free Cash Flow, both liquidity measures that exclude charges or liabilities that require cash settlement. Please refer to Item 10(e)(1)(ii)(A) of Regulation S-K, which prohibits the exclusion of charges or liabilities that required, or will require, cash settlement, or would have required cash settlement, absent an ability to settle in another manner, from non- GAAP liquidity measures and revise accordingly. Note 2. Significant Accounting Policies Revenue Recognition , page F-10 2.You disclose that usage based fees represent variable consideration, but that the Company
FirstName LastNameSteven Berns Comapany NameGTT Communications, Inc. April 21, 2020 Page 2 FirstName LastName Steven Berns GTT Communications, Inc. April 21, 2020 Page 2 is not able to "estimate these amounts with a high degree of certainty and therefore the usage based fees are excluded from the transaction price and are instead recognized as revenue based on actual usage charges billed using the rates and/or thresholds specified in each contract." Please describe the factors that you considered in assessing the likelihood and the magnitude of a revenue reversal in applying the variable consideration constraint. Refer to ASC 606-10-32-11 through 32-13. Also, tell us the actual usage fee revenues recognized during each of the periods presented. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert Littlepage, Accountant Branch Chief at (202) 551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
Show Raw Text
April 21, 2020
Steven Berns
Chief Financial Officer
GTT Communications, Inc.
7900 Tysons One Place
Suite 1450
McLean, VA 22102
Re:GTT Communications, Inc.
Form 10-K for the Year Ended December 31,2019
Filed March 2, 2020
File No. 001-35965
Dear Mr. Berns:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31,2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures, page 31
1.We note that you present Adjusted Free Cash Flow and Adjusted Unlevered Free Cash
Flow, both liquidity measures that exclude charges or liabilities that require cash
settlement. Please refer to Item 10(e)(1)(ii)(A) of Regulation S-K, which prohibits the
exclusion of charges or liabilities that required, or will require, cash settlement, or would
have required cash settlement, absent an ability to settle in another manner, from non-
GAAP liquidity measures and revise accordingly.
Note 2. Significant Accounting Policies
Revenue Recognition , page F-10
2.You disclose that usage based fees represent variable consideration, but that the Company
FirstName LastNameSteven Berns
Comapany NameGTT Communications, Inc.
April 21, 2020 Page 2
FirstName LastName
Steven Berns
GTT Communications, Inc.
April 21, 2020
Page 2
is not able to "estimate these amounts with a high degree of certainty and therefore the
usage based fees are excluded from the transaction price and are instead recognized as
revenue based on actual usage charges billed using the rates and/or thresholds specified in
each contract." Please describe the factors that you considered in assessing the likelihood
and the magnitude of a revenue reversal in applying the variable consideration constraint.
Refer to ASC 606-10-32-11 through 32-13. Also, tell us the actual usage fee revenues
recognized during each of the periods presented.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology