SEC Comment Letter 0000000000-23-000835 to Everpure, Inc. (PSTG)
Everpure, Inc.
Date: Jan. 25, 2023 · CIK: 0001474432 · Accession: 0000000000-23-000835
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37570
Letter
United States securities and exchange commission logo January 25, 2023 Charles Giancarlo Chief Executive Officer Pure Storage, Inc. 650 Castro Street, Suite 400 Mountain View, California 94041 Re:Pure Storage, Inc. Form 10-K for Fiscal Year Ended February 6, 2022 Filed April 7, 2022 File No. 001-37570 Dear Charles Giancarlo: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In some of our comments, we may 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-K for Fiscal Year Ended February 6, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 1.You disclose pre-tax earnings from foreign operations of $18.0M, $41.96M and $63.56M in the 2020, 2021 and 2022 fiscal years in Note 15. You also disclose significant pre-tax losses from domestic operations of $212.67M, $312.12M and $192.06M in the 2020, 2021 and 2022 fiscal years in Note 15. You discuss your results on a consolidated basis and state that you have recorded no U.S. Federal current income tax and provided a full valuation allowance for U.S. deferred tax assets. However, it is unclear from your discussion what underlying factors are driving these disparate domestic and foreign operating results. Please discuss and analyze the factors driving your pre-tax earnings from foreign operations and your pre-tax losses from domestic operations. Also disclose qualitative and quantitative reasons for any material changes in results or known trends in your domestic and international operations. Refer to the guidance in Item 303 of
FirstName LastNameCharles Giancarlo Comapany NamePure Storage, Inc. January 25, 2023 Page 2 FirstName LastName Charles Giancarlo Pure Storage, Inc. January 25, 2023 Page 2 Regulation S-K and SEC Release No. 33-8350. In closing, 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 Sondra Snyder, Staff Accountant at (202) 551-3332 or Gus Rodriguez, Accounting Branch Chief at (202) 551-3752 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
January 25, 2023
Charles Giancarlo
Chief Executive Officer
Pure Storage, Inc.
650 Castro Street, Suite 400
Mountain View, California 94041
Re:Pure Storage, Inc.
Form 10-K for Fiscal Year Ended February 6, 2022
Filed April 7, 2022
File No. 001-37570
Dear Charles Giancarlo:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In some of our comments, we may 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-K for Fiscal Year Ended February 6, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
40
1.You disclose pre-tax earnings from foreign operations of $18.0M, $41.96M and $63.56M
in the 2020, 2021 and 2022 fiscal years in Note 15. You also disclose significant pre-tax
losses from domestic operations of $212.67M, $312.12M and $192.06M in the 2020, 2021
and 2022 fiscal years in Note 15. You discuss your results on a consolidated basis and
state that you have recorded no U.S. Federal current income tax and provided a full
valuation allowance for U.S. deferred tax assets. However, it is unclear from your
discussion what underlying factors are driving these disparate domestic and foreign
operating results. Please discuss and analyze the factors driving your pre-tax earnings
from foreign operations and your pre-tax losses from domestic operations. Also disclose
qualitative and quantitative reasons for any material changes in results or known trends in
your domestic and international operations. Refer to the guidance in Item 303 of
FirstName LastNameCharles Giancarlo
Comapany NamePure Storage, Inc.
January 25, 2023 Page 2
FirstName LastName
Charles Giancarlo
Pure Storage, Inc.
January 25, 2023
Page 2
Regulation S-K and SEC Release No. 33-8350.
In closing, 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 Sondra Snyder, Staff Accountant at (202) 551-3332 or Gus Rodriguez,
Accounting Branch Chief at (202) 551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation