SEC Comment Letter for Palo Alto Networks Inc (PANW) (CIK 0001327567) (PANW) — Jun 14, 2019
Palo Alto Networks Inc (PANW) (CIK 0001327567)
Date: June 14, 2019 · CIK: 0001327567 · Accession: 0000000000-19-009894
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35594
Letter
June 14, 2019 Nikesh Arora Chief Executive Officer Palo Alto Networks, Inc. 3000 Tannery Way Santa Clara, California 95054 Re:Palo Alto Networks, Inc. Form 10-K for the Fiscal Year Ended July 31, 2018 Form 10-Q for the Quarterly Period Ended April 30,2019 File No. 001-35594 Dear Mr. Arora: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In some of our comments, 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the Quarterly Period Ended April 30,2019 Revenue Recognition, page 12 1.We note that the majority of your contracts with your customers include various combinations of your products and subscriptions and support which are distinct and accounted for as separate performance obligations. We further note that when end- customers purchase your physical or virtual firewall appliances, they typically purchase support in order to receive ongoing security updates, upgrades, bug fixes, and repairs. Please explain how you considered the guidance in ASC 606-10-25-21 and Example 10, Case C included in ASC 606-10-55-140D.
FirstName LastNameNikesh Arora Comapany NamePalo Alto Networks, Inc. June 14, 2019 Page 2 FirstName LastName Nikesh Arora Palo Alto Networks, Inc. June 14, 2019 Page 2 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 Morgan Youngwood, Staff Accountant, at 202-551-3479 or Craig Wilson, Senior Assistant Chief Accountant, at 202-551-3226 with any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services
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June 14, 2019
Nikesh Arora
Chief Executive Officer
Palo Alto Networks, Inc.
3000 Tannery Way
Santa Clara, California 95054
Re:Palo Alto Networks, Inc.
Form 10-K for the Fiscal Year Ended July 31, 2018
Form 10-Q for the Quarterly Period Ended April 30,2019
File No. 001-35594
Dear Mr. Arora:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In some of our comments, 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended April 30,2019
Revenue Recognition, page 12
1.We note that the majority of your contracts with your customers include various
combinations of your products and subscriptions and support which are distinct and
accounted for as separate performance obligations. We further note that when end-
customers purchase your physical or virtual firewall appliances, they typically purchase
support in order to receive ongoing security updates, upgrades, bug fixes, and repairs.
Please explain how you considered the guidance in ASC 606-10-25-21 and Example 10,
Case C included in ASC 606-10-55-140D.
FirstName LastNameNikesh Arora
Comapany NamePalo Alto Networks, Inc.
June 14, 2019 Page 2
FirstName LastName
Nikesh Arora
Palo Alto Networks, Inc.
June 14, 2019
Page 2
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 Morgan Youngwood, Staff Accountant, at 202-551-3479 or Craig
Wilson, Senior Assistant Chief Accountant, at 202-551-3226 with any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services