SEC Comment Letter for Workday, Inc. (WDAY) (CIK 0001327811) (WDAY) — Aug 25, 2017
Workday, Inc. (WDAY) (CIK 0001327811)
Date: Aug. 25, 2017 · CIK: 0001327811 · Accession: 0000000000-17-030166
AI Filing Summary & Sentiment
Letter
August 2 5, 2017 Robynne Sisco 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, 2017 Filed March 20, 2017 Form 10 -Q for the quarter ended April 30, 2017 Filed June 2, 2017 File No. 001 -35680
Dear Ms. Sisco :
We have reviewed your August 8, 2017 response to our comment letter and 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 comment 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 comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to com ments in our July 26 , 2017 letter .
Form 10 -Q for the quarter ended April 30, 2017
Notes to Condensed Consolidated Financial Statements
Note 2. Accounting Standards and Significant Accounting Policies
Revenue Recognition, page 10
1. We note your res ponse to prior comment 2. Please revise to disclose the method by which you amortize the initial commission costs over the five -year period of benefit. Please also disclose the method and period of time over which you amortize commission costs related to subsequent contract renewals. Refer to ASC 340 -40-50-2.
Robynne Sisco Workday, Inc. August 2 5, 2017 Page 2
You may contact Brittany Ebbertt, Staff Accountant , at (202) 551 -3572 or me at (202) 551-3499 with any questions.
Sincerely,
/s/ Kathleen Collins
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August 2 5, 2017 Robynne Sisco 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, 2017 Filed March 20, 2017 Form 10 -Q for the quarter ended April 30, 2017 Filed June 2, 2017 File No. 001 -35680 Dear Ms. Sisco : We have reviewed your August 8, 2017 response to our comment letter and 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 comment 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 comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to com ments in our July 26 , 2017 letter . Form 10 -Q for the quarter ended April 30, 2017 Notes to Condensed Consolidated Financial Statements Note 2. Accounting Standards and Significant Accounting Policies Revenue Recognition, page 10 1. We note your res ponse to prior comment 2. Please revise to disclose the method by which you amortize the initial commission costs over the five -year period of benefit. Please also disclose the method and period of time over which you amortize commission costs related to subsequent contract renewals. Refer to ASC 340 -40-50-2. Robynne Sisco Workday, Inc. August 2 5, 2017 Page 2 You may contact Brittany Ebbertt, Staff Accountant , at (202) 551 -3572 or me at (202) 551-3499 with any questions. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services cc: Jim Shaughnessy, Senior Vice President, General Counsel and Secretary Jeffrey Vetter, Legal Counsel, Fenwick & West