SEC Company Response from Workday, Inc. (WDAY) (CIK 0001327811) (WDAY) — Aug 31, 2017
Workday, Inc. (WDAY) (CIK 0001327811)
Date: Aug. 31, 2017 · CIK: 0001327811 · Accession: 0001193125-17-274606
AI Filing Summary & Sentiment
Referenced dates: August 25, 2017
Letter
Re: Workday, Inc.
August 31, 2017
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549-3720
Form 10-K for the year ended January 31, 2017
Filed March 20, 2017
Form 10-Q for the quarter ended April 30, 2017
Filed June 2, 2017
Ladies and Gentlemen:
On behalf of Workday, Inc. (“Workday”), set forth below is Workday’s response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the letter dated August 25, 2017. For ease of reference, the numbered paragraphs below correspond to the numbered comments in that letter; the Staff’s comments are presented in bold italics.
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 response 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.
Workday advises the Staff that in response to the Staff’s comment it has updated its disclosure of use of estimates, critical accounting policies and deferred commissions in the Notes to Condensed Consolidated Financial Statements included on pages 9, 10, 14 and in the Management’s Discussion and Analysis of Financial Condition and Results of Operations on pages 30, 41 and 42 in in its Form 10-Q for the quarter ended July 31, 2017 filed on August 31, 2017.
6230 Stoneridge Mall Road, Pleasanton CA 94588 United States / main +1.925.951.9000 fax +1.925-951.9001 www.workday.com
Securities and Exchange Commission
August 31, 2017
Page 2
If you have any further questions, please feel free to contact the undersigned or Jeffrey Vetter of Fenwick & West LLP at (650) 335-7631.
Sincerely,
Workday, Inc.
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CORRESP 1 filename1.htm CORRESP August 31, 2017 Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549-3720 Re: Workday, Inc. Form 10-K for the year ended January 31, 2017 Filed March 20, 2017 Form 10-Q for the quarter ended April 30, 2017 Filed June 2, 2017 Ladies and Gentlemen: On behalf of Workday, Inc. (“Workday”), set forth below is Workday’s response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the letter dated August 25, 2017. For ease of reference, the numbered paragraphs below correspond to the numbered comments in that letter; the Staff’s comments are presented in bold italics. 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 response 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. Workday advises the Staff that in response to the Staff’s comment it has updated its disclosure of use of estimates, critical accounting policies and deferred commissions in the Notes to Condensed Consolidated Financial Statements included on pages 9, 10, 14 and in the Management’s Discussion and Analysis of Financial Condition and Results of Operations on pages 30, 41 and 42 in in its Form 10-Q for the quarter ended July 31, 2017 filed on August 31, 2017. 6230 Stoneridge Mall Road, Pleasanton CA 94588 United States / main +1.925.951.9000 fax +1.925-951.9001 www.workday.com Securities and Exchange Commission August 31, 2017 Page 2 If you have any further questions, please feel free to contact the undersigned or Jeffrey Vetter of Fenwick & West LLP at (650) 335-7631. Sincerely, Workday, Inc. /s/ Robynne D. Sisco Robynne D. Sisco Chief Financial Officer Cc: Aneel Bhusri, Chief Executive Officer Trish Coughlin, Corporate Controller James P. Shaughnessy, Esq., Senior Vice President, General Counsel and Secretary Melanie D. Vinson, Esq., Deputy General Counsel, Corporate Workday, Inc. Gordon K. Davidson, Esq. Jeffery R. Vetter, Esq. Fenwick & West LLP Dave Cabral Ernst & Young LLP