SEC Company Response from Pure Storage, Inc. (PSTG) (CIK 0001474432) (P) — Oct 1, 2015
Pure Storage, Inc. (PSTG) (CIK 0001474432)
Date: Oct. 1, 2015 · CIK: 0001474432 · Accession: 0001193125-15-334451
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-206312
Referenced dates: September 25, 2015
Letter
John T. McKenna
+1 650 843
jmckenna@cooley.com
October 1, 2015
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, DC 20549
Attn: Ji Shin, Attorney-Advisor
Barbara C. Jacobs, Assistant Director
RE: Pure Storage, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed September 24, 2015
File No. 333-206312
Ladies and Gentlemen:
On behalf of Pure Storage, Inc. (the “Company”), we are providing this letter in response to the comment (the “Comment”) received from the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) by letter dated September 25, 2015 with respect to the Company’s Amendment No. 2 to Registration Statement on Form S-1, filed on September 24, 2015. The Company is concurrently filing a Registration Statement on Form S-1 (the “Registration Statement”).
Set forth below is the Company’s response to the Comment. The numbering of the paragraph below corresponds to the numbering of the Comment, which for your convenience we have incorporated into this response letter.
Notes to Consolidated Financial Statements
Note 15. Subsequent Events, page F-31
1. Please expand your disclosure regarding the options granted in September 2015 to include the aggregate grant date fair value, the periods and related amounts in which the fair value will be recognized as stock-based compensation expense. See ASC 855-10-50-2b.
The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on page F-31 of the Registration Statement.
* * *
3175 HANOVER STREET, PALO ALTO, CA 94304 T: (650) 843-5000 F: (650) 849-7400 WWW.COOLEY.COM
U.S. Securities and Exchange Commission
October 1, 2015
Page Two
Please contact me at (650) 843-5059 with any questions or further comments regarding our response to the Staff’s Comment.
Sincerely,
/s/ John T. McKenna
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CORRESP 1 filename1.htm CORRESP John T. McKenna +1 650 843 5059 jmckenna@cooley.com October 1, 2015 U.S. Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, DC 20549 Attn: Ji Shin, Attorney-Advisor Barbara C. Jacobs, Assistant Director RE: Pure Storage, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed September 24, 2015 File No. 333-206312 Ladies and Gentlemen: On behalf of Pure Storage, Inc. (the “Company”), we are providing this letter in response to the comment (the “Comment”) received from the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) by letter dated September 25, 2015 with respect to the Company’s Amendment No. 2 to Registration Statement on Form S-1, filed on September 24, 2015. The Company is concurrently filing a Registration Statement on Form S-1 (the “Registration Statement”). Set forth below is the Company’s response to the Comment. The numbering of the paragraph below corresponds to the numbering of the Comment, which for your convenience we have incorporated into this response letter. Notes to Consolidated Financial Statements Note 15. Subsequent Events, page F-31 1. Please expand your disclosure regarding the options granted in September 2015 to include the aggregate grant date fair value, the periods and related amounts in which the fair value will be recognized as stock-based compensation expense. See ASC 855-10-50-2b. The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on page F-31 of the Registration Statement. * * * 3175 HANOVER STREET, PALO ALTO, CA 94304 T: (650) 843-5000 F: (650) 849-7400 WWW.COOLEY.COM U.S. Securities and Exchange Commission October 1, 2015 Page Two Please contact me at (650) 843-5059 with any questions or further comments regarding our response to the Staff’s Comment. Sincerely, /s/ John T. McKenna John T. McKenna cc: Scott Dietzen, Pure Storage, Inc. Joseph FitzGerald, Pure Storage, Inc. Todd Wheeler, Pure Storage, Inc. Mark P. Tanoury, Cooley LLP Seth J. Gottlieb, Cooley LLP Alex K. Kassai, Cooley LLP Alan F. Denenberg, Davis Polk & Wardwell LLP 3175 HANOVER STREET, PALO ALTO, CA 94304 T: (650) 843-5000 F: (650) 849-7400 WWW.COOLEY.COM