SEC Comment Letter for Workday, Inc. (WDAY) (CIK 0001327811) (WDAY) — May 21, 2015
Workday, Inc. (WDAY) (CIK 0001327811)
Date: May 21, 2015 · CIK: 0001327811 · Accession: 0000000000-15-027646
AI Filing Summary & Sentiment
File numbers found in text: 001-35680
Letter
May 21, 2015 Mark S. Peek Chief Financial Officer Workday, Inc. 6230 Stoneridge Mall Road Pleasanton, CA 94588
Re: Workday, Inc. Form 10 -K for the Fiscal Year Ended January 31, 2015 Filed March 25, 2015 File No. 001-35680
Dear Mr. Peek :
We have reviewed your filing 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 r esponse.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended January 31, 2015
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Overview, page 27
1. Please consider expanding your overview section to provide insight into material opportunities, challenges and risks, such as those presented by known ma terial trends and uncertainties, on which your executives are most focused for both the short - and long - term and the actions that you are taking to address these opportunities, challenges and risks. Specifically , we note your discussion regarding plans to expand your global presence in your February 25, 2015 earnings call . Consider including a more detailed discussion of these plans in your overview section in future filings. For additional guidance, consider Section III.A of SEC Release No. 33-8350.
Mark S. Peek Workday, Inc. May 21, 2015 Page 2
Results of Operations
Revenues, page 29
2. We note your statement that a substantial majority of your growth comes from new customers. Please tell us what consideration you have given to quantifying the number of new and existing customers and to quantifying any increases in revenue attributable to new versus existing customer s. In this regard, we note that you provided quantitative disclosure in prior years.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securiti es Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions, please contact Mitchell Austin, Staff Attorney, at (202) 551 - 3574 or Maryse Mills -Apenteng, Special Counsel, at (202) 551 -3457 . If you require further assistance, do not hesit ate to contact me at (202) 551 -3226 .
Sincerely,
/s/ Craig D. Wilson
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May 21, 2015 Mark S. Peek Chief Financial Officer Workday, Inc. 6230 Stoneridge Mall Road Pleasanton, CA 94588 Re: Workday, Inc. Form 10 -K for the Fiscal Year Ended January 31, 2015 Filed March 25, 2015 File No. 001-35680 Dear Mr. Peek : We have reviewed your filing 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 r esponse. After reviewing your response to these comments, we may have additional comments. Form 10 -K for the Fiscal Year Ended January 31, 2015 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Overview, page 27 1. Please consider expanding your overview section to provide insight into material opportunities, challenges and risks, such as those presented by known ma terial trends and uncertainties, on which your executives are most focused for both the short - and long - term and the actions that you are taking to address these opportunities, challenges and risks. Specifically , we note your discussion regarding plans to expand your global presence in your February 25, 2015 earnings call . Consider including a more detailed discussion of these plans in your overview section in future filings. For additional guidance, consider Section III.A of SEC Release No. 33-8350. Mark S. Peek Workday, Inc. May 21, 2015 Page 2 Results of Operations Revenues, page 29 2. We note your statement that a substantial majority of your growth comes from new customers. Please tell us what consideration you have given to quantifying the number of new and existing customers and to quantifying any increases in revenue attributable to new versus existing customer s. In this regard, we note that you provided quantitative disclosure in prior years. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securiti es Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If you have any questions, please contact Mitchell Austin, Staff Attorney, at (202) 551 - 3574 or Maryse Mills -Apenteng, Special Counsel, at (202) 551 -3457 . If you require further assistance, do not hesit ate to contact me at (202) 551 -3226 . Sincerely, /s/ Craig D. Wilson Craig D. Wilson Senior Assistant Chief Accountant