SEC Comment Letter for Pure Storage, Inc. (PSTG) (CIK 0001474432) (P) — Nov 13, 2017
Pure Storage, Inc. (PSTG) (CIK 0001474432)
Date: Nov. 13, 2017 · CIK: 0001474432 · Accession: 0000000000-17-040068
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4628 November 13 , 201 7 Via E-Mail Timothy Riitters Chief Financial Officer Pure Storage, Inc. 650 Castro Street, Suite 400 Mountain View, CA 94041
Re: Pure Storage, Inc. Form 10-K for the Fiscal Year Ended January 31, 2017 Filed March 29 , 2017 File No. 1-37570
Dear Mr. Riitters :
We have limited our review of your filing to your contacts with countries that have been identified as state sponsors of terrorism, and we have the following comments. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. In our comments , we 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.
General
1. You state on page 13 that, in addition to selling your products, your partners may offer installation, post -sale service and support on your behalf in their local markets. You identify Cisco and Microsoft as partners on pages 5 and 7. Both companies discussed sales to Syria and Sudan in publicly available letters to us in 2014. Syria and Sudan are designated by the State Department as s tate sponsors of terrorism, and are subject to U.S. economic sanctions and/or export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with Syria and Sudan, whether through subsidiaries, affiliates, distr ibutors, joint venture partners, or other direct or indirect arrangements. You should describe any products, components, technology or services you have provided to Syria or Sudan, directly or indirectly, and any agreements, commercial arrangements or oth er contacts with the governments of those countries or
Timothy Riitters Pure Storage, Inc. November 13 , 2017 Page 2
entities they control.
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 Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 - 3470 if you have any questions about the comments or our review.
Sincerely,
/s/ Cecilia Bl ye
Show Raw Text
Mail Stop 4628 November 13 , 201 7 Via E-Mail Timothy Riitters Chief Financial Officer Pure Storage, Inc. 650 Castro Street, Suite 400 Mountain View, CA 94041 Re: Pure Storage, Inc. Form 10-K for the Fiscal Year Ended January 31, 2017 Filed March 29 , 2017 File No. 1-37570 Dear Mr. Riitters : We have limited our review of your filing to your contacts with countries that have been identified as state sponsors of terrorism, and we have the following comments. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. In our comments , we 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. General 1. You state on page 13 that, in addition to selling your products, your partners may offer installation, post -sale service and support on your behalf in their local markets. You identify Cisco and Microsoft as partners on pages 5 and 7. Both companies discussed sales to Syria and Sudan in publicly available letters to us in 2014. Syria and Sudan are designated by the State Department as s tate sponsors of terrorism, and are subject to U.S. economic sanctions and/or export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with Syria and Sudan, whether through subsidiaries, affiliates, distr ibutors, joint venture partners, or other direct or indirect arrangements. You should describe any products, components, technology or services you have provided to Syria or Sudan, directly or indirectly, and any agreements, commercial arrangements or oth er contacts with the governments of those countries or Timothy Riitters Pure Storage, Inc. November 13 , 2017 Page 2 entities they control. 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 Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 - 3470 if you have any questions about the comments or our review. Sincerely, /s/ Cecilia Bl ye Cecilia Blye, Chief Office of Global Security Risk cc: John T. McKenna, Esq. Cooley LLP Barbara Jacobs Assistant Director