SEC Comment Letter for AVIAT NETWORKS, INC. (AVNW) (CIK 0001377789) (AVNW) — Jun 25, 2019
AVIAT NETWORKS, INC. (AVNW) (CIK 0001377789)
Date: June 25, 2019 · CIK: 0001377789 · Accession: 0000000000-19-010302
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33278
Letter
June 25, 2019 Walter Stanley Gallagher, Jr. Chief Operating Officer and Principal Financial Officer Aviat Networks, Inc. 860 N. McCarthy Blvd., Suite 200 Milpitas, California 95035 Re:Aviat Networks, Inc. 10-K for the Year Ended June 30, 2018 Filed August 28, 2018 Form 10-Q for the Quarter Ended March 29, 2019 Filed May 13, 2019 File No. 001-33278 Dear Mr. Gallagher: We have reviewed your filing and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the Quarter Ended March 29, 2019 Note 3. Revenue Recognition, page 13 1.We note under bill-and-hold arrangements, customers can direct the use of the bill-and- hold inventory for which you retain physical possession and thus, "transfer of control has been met." Please explain to us how you applied the guidance in ASC 606-10-25-30 in concluding that a customer has obtained control in a bill-and-hold arrangement. Additionally, in your assessment of transfer of control, tell us how each of the criteria under ASC 606-10-55-83 has been met. 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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
FirstName LastNameWalter Stanley Gallagher, Jr. Comapany NameAviat Networks, Inc. June 25, 2019 Page 2 FirstName LastName Walter Stanley Gallagher, Jr. Aviat Networks, Inc. June 25, 2019 Page 2 Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Telecommunications
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June 25, 2019
Walter Stanley Gallagher, Jr.
Chief Operating Officer and Principal Financial Officer
Aviat Networks, Inc.
860 N. McCarthy Blvd., Suite 200
Milpitas, California 95035
Re:Aviat Networks, Inc.
10-K for the Year Ended June 30, 2018
Filed August 28, 2018
Form 10-Q for the Quarter Ended March 29, 2019
Filed May 13, 2019
File No. 001-33278
Dear Mr. Gallagher:
We have reviewed your filing and have the following comment. In our comment, we ask
you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarter Ended March 29, 2019
Note 3. Revenue Recognition, page 13
1.We note under bill-and-hold arrangements, customers can direct the use of the bill-and-
hold inventory for which you retain physical possession and thus, "transfer of control has
been met." Please explain to us how you applied the guidance in ASC 606-10-25-30 in
concluding that a customer has obtained control in a bill-and-hold arrangement.
Additionally, in your assessment of transfer of control, tell us how each of the criteria
under ASC 606-10-55-83 has been met.
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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
FirstName LastNameWalter Stanley Gallagher, Jr.
Comapany NameAviat Networks, Inc.
June 25, 2019 Page 2
FirstName LastName
Walter Stanley Gallagher, Jr.
Aviat Networks, Inc.
June 25, 2019
Page 2
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Telecommunications