SEC Comment Letter for Under Armour, Inc. (UA, UAA) (CIK 0001336917) (UA) — May 23, 2018
Under Armour, Inc. (UA, UAA) (CIK 0001336917)
Date: May 23, 2018 · CIK: 0001336917 · Accession: 0000000000-18-015926
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 May 23 , 2018 Via E -mail David E. Bergman Chief Financial Officer Under Armour, Inc. 1020 Hull Street Baltimore, Maryland 21230
Re: Under Armour, Inc. Form 10 -K for Fiscal Year Ended December 31, 2017 Filed February 28, 2018 Form 8 -K Filed May 1, 2018 File No. 001 -33202
Dear Mr. Bergman :
We have reviewed your filing an d 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 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 comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2017
Notes to the Audited Consolidated Financial Statements 2 . Summary of Significant Accounting Policies Goodwill, Intangible Assets and Long -Lived Assets , page 59
1. You state that as of December 31, 2017, no impairment of goodwill was identified and the fair value of each reporting unit subst antially exceeded its carrying value. We also note that your Latin American segment has experienced operating losses in the past three years. Please provide us with an analysis that supports your assertion for your Latin American segment.
David E. Bergman Under Armour, Inc. May 23 , 2018 Page 2
Form 8 -K File d May 1, 2018 Exhibit 99.1
2. You present a full non -GAAP income statement for the quarter ended March 31, 2018 when reconciling non -GAAP measures to the most directly comparable GAAP measures. Please tell us how your presentation complies with the guidance in Question 102.10 of the Non -GAAP Compliance and Disclosure Interpretations .
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, no twithstanding any review, comments, action or absence of action by the staff.
You may contact Suying Li at (202) 551 -3335 or me at (202) 551 -3651 with any questions.
Sincerely,
/s/ Joel Parker
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Mail Stop 3561 May 23 , 2018 Via E -mail David E. Bergman Chief Financial Officer Under Armour, Inc. 1020 Hull Street Baltimore, Maryland 21230 Re: Under Armour, Inc. Form 10 -K for Fiscal Year Ended December 31, 2017 Filed February 28, 2018 Form 8 -K Filed May 1, 2018 File No. 001 -33202 Dear Mr. Bergman : We have reviewed your filing an d 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 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2017 Notes to the Audited Consolidated Financial Statements 2 . Summary of Significant Accounting Policies Goodwill, Intangible Assets and Long -Lived Assets , page 59 1. You state that as of December 31, 2017, no impairment of goodwill was identified and the fair value of each reporting unit subst antially exceeded its carrying value. We also note that your Latin American segment has experienced operating losses in the past three years. Please provide us with an analysis that supports your assertion for your Latin American segment. David E. Bergman Under Armour, Inc. May 23 , 2018 Page 2 Form 8 -K File d May 1, 2018 Exhibit 99.1 2. You present a full non -GAAP income statement for the quarter ended March 31, 2018 when reconciling non -GAAP measures to the most directly comparable GAAP measures. Please tell us how your presentation complies with the guidance in Question 102.10 of the Non -GAAP Compliance and Disclosure Interpretations . We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, no twithstanding any review, comments, action or absence of action by the staff. You may contact Suying Li at (202) 551 -3335 or me at (202) 551 -3651 with any questions. Sincerely, /s/ Joel Parker Joel Parker Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining