SEC Comment Letter for ServiceNow, Inc. (NOW) (CIK 0001373715) (NOW) — Aug 2, 2019
ServiceNow, Inc. (NOW) (CIK 0001373715)
Date: Aug. 2, 2019 · CIK: 0001373715 · Accession: 0000000000-19-011955
AI Filing Summary & Sentiment
File numbers found in text: 001-35580
Letter
August 1, 2019 Fay Sien Goon Chief Accounting Officer ServiceNow, Inc. 2225 Lawson Lane Santa Clara, CA 95054 Re:ServiceNow, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 27, 2019 File No. 001-35580 Dear Ms. Goon: 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 response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2018 Note 2. Summary of Significant Accounting Policies Revenue from Contracts with Customers, page 75 1.You disclose that you defer indirect costs that are not tied to a specific customer contract. Please explain the nature and amount of these costs for each period presented and your basis for capitalizing them. Refer to ASC 340-40-25. Note 17. Income Taxes, page 95 2.Please describe the nature of the foreign tax restructuring in 2018 that gave rise to the $590 million in deferred tax assets and revise your disclosures to describe the restructuring. Also, confirm whether these are the same deferred tax assets of your Irish subsidiary referred to in the March 31, 2019 Form 10-Q that would give rise to an income tax benefit in excess of $500 million if the valuation allowance were released. If they are the same, revise your disclosures to clarify.
FirstName LastNameFay Sien Goon Comapany NameServiceNow, Inc. August 1, 2019 Page 2 FirstName LastName Fay Sien Goon ServiceNow, Inc. August 1, 2019 Page 2 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 Frank Knapp, Staff Accountant at (202) 551-3805 or Christine Dietz, Assistant Chief Accountant at (202) 551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services cc: Russell Elmer
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August 1, 2019
Fay Sien Goon
Chief Accounting Officer
ServiceNow, Inc.
2225 Lawson Lane
Santa Clara, CA 95054
Re:ServiceNow, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 27, 2019
File No. 001-35580
Dear Ms. Goon:
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 response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2018
Note 2. Summary of Significant Accounting Policies
Revenue from Contracts with Customers, page 75
1.You disclose that you defer indirect costs that are not tied to a specific customer contract.
Please explain the nature and amount of these costs for each period presented and your
basis for capitalizing them. Refer to ASC 340-40-25.
Note 17. Income Taxes, page 95
2.Please describe the nature of the foreign tax restructuring in 2018 that gave rise to the
$590 million in deferred tax assets and revise your disclosures to describe the
restructuring. Also, confirm whether these are the same deferred tax assets of your Irish
subsidiary referred to in the March 31, 2019 Form 10-Q that would give rise to an income
tax benefit in excess of $500 million if the valuation allowance were released. If they are
the same, revise your disclosures to clarify.
FirstName LastNameFay Sien Goon
Comapany NameServiceNow, Inc.
August 1, 2019 Page 2
FirstName LastName
Fay Sien Goon
ServiceNow, Inc.
August 1, 2019
Page 2
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 Frank Knapp, Staff Accountant at (202) 551-3805 or Christine Dietz,
Assistant Chief Accountant at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services
cc: Russell Elmer