SEC Comment Letter for Palo Alto Networks Inc (PANW) (CIK 0001327567) (PANW) — Mar 17, 2014
Palo Alto Networks Inc (PANW) (CIK 0001327567)
Date: March 17, 2014 · CIK: 0001327567 · Accession: 0000000000-14-013106
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 14, 2014, February 24, 2014
Letter
March 14, 2014 Via E -mail Mark D. McLaughlin President and CEO Palo Alto Networks, Inc. 4401 Great America Parkway Santa Clara, California 95054
Re: Palo Alto Networks, Inc. Form 10-K for the Fiscal Year Ended July 31, 2013 Filed September 25, 2013 File No. 001 -35594
Dear Mr. McLaughlin :
We have reviewed you r letter dated February 24, 2014 in connection with the above - referenced filing an d 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you w ill provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the infor mation you provide in response to this comment, we may have additional comments . Unless otherwise noted, where prior comments are referred to they refer to our letter dated February 14, 2014 .
Form 10 -K for the Fis cal Year Ended July 31, 2013
Consolida ted Financial Statements
Note 8. Income Taxes, page 77
1. We note your response to prior comment 4. Please explain in greater detail how the share -based compensation and foreign rate differentials are determined in each fiscal year presented and identify the significant components of these items. A s part of your response, please explain why your share -based compensation rate differential decreased from 66.6% to (16.1%) describing the type of option grants and related income tax accounting and why the line item, “Foreign income at other than U.S. rates” decreased
Mark D. McLaughlin Palo Alto Networks, Inc. March 14, 2014 Page 2
from 17.2% to (62.4%) between fiscal 2012 and 2013. In this regard, please explain the relationships among pre -tax earnings (loss) and the non -U.S. revenues disclosed in Note 12, page 81.
You may contact Morgan Youngwood, Staff Accountant, at (202) 551-3479 if you have any questions regarding comments on the financial statements and related matters . Please contact me at (202) 551 -3730 with any other questions.
Sincerely,
/s/ Craig D. Wilson
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March 14, 2014 Via E -mail Mark D. McLaughlin President and CEO Palo Alto Networks, Inc. 4401 Great America Parkway Santa Clara, California 95054 Re: Palo Alto Networks, Inc. Form 10-K for the Fiscal Year Ended July 31, 2013 Filed September 25, 2013 File No. 001 -35594 Dear Mr. McLaughlin : We have reviewed you r letter dated February 24, 2014 in connection with the above - referenced filing an d 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you w ill provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the infor mation you provide in response to this comment, we may have additional comments . Unless otherwise noted, where prior comments are referred to they refer to our letter dated February 14, 2014 . Form 10 -K for the Fis cal Year Ended July 31, 2013 Consolida ted Financial Statements Note 8. Income Taxes, page 77 1. We note your response to prior comment 4. Please explain in greater detail how the share -based compensation and foreign rate differentials are determined in each fiscal year presented and identify the significant components of these items. A s part of your response, please explain why your share -based compensation rate differential decreased from 66.6% to (16.1%) describing the type of option grants and related income tax accounting and why the line item, “Foreign income at other than U.S. rates” decreased Mark D. McLaughlin Palo Alto Networks, Inc. March 14, 2014 Page 2 from 17.2% to (62.4%) between fiscal 2012 and 2013. In this regard, please explain the relationships among pre -tax earnings (loss) and the non -U.S. revenues disclosed in Note 12, page 81. You may contact Morgan Youngwood, Staff Accountant, at (202) 551-3479 if you have any questions regarding comments on the financial statements and related matters . Please contact me at (202) 551 -3730 with any other questions. Sincerely, /s/ Craig D. Wilson Craig D. Wilson Senior Assistant Chief Accountant