SEC Comment Letter for STRATASYS LTD. (SSYS) (CIK 0001517396) (SSYS) — Aug 8, 2019
STRATASYS LTD. (SSYS) (CIK 0001517396)
Date: Aug. 8, 2019 · CIK: 0001517396 · Accession: 0000000000-19-012217
AI Filing Summary & Sentiment
File numbers found in text: 001-35751
Letter
August 8, 2019 S. Scott Crump Chairman of Executive Committee Stratasys Ltd. 7665 Commerce Way Eden Prairie, Minnesota 55344 Re:Stratasys Ltd Form F-20 for the fiscal year ended December 31, 2018 Filed on March 07, 2019 File No. 001-35751 Dear Mr. Crump: We have limited our review of your filing to the financial statements and related disclosures 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 F-20 filed March 07, 2019 Notes to consolidated financial statements Note 10. Commitments and Contingencies Contingencies, page F-32 1.We note that you disclose the Patent Law-Based Claim initiated on November 23, 2017 on page F-32, and you indicate that you reject the claims that serve as a basis for the proceeding and intend to vigorously defend these claims. In accordance with ASC 450- 20-50, please revise future filings to clearly disclose the following information for your loss contingencies: (1) the amount or range of reasonably possible losses in addition to the amounts accrued or (2) a statement that the reasonably possible losses cannot be estimated or are not material to your financial statements. 2.We note that the Company is a party to various other legal proceedings, the outcome of which, in the opinion of management, will not have a significant adverse effect on the financial position or profitability of the Company. With a view toward future disclosure,
FirstName LastNameS. Scott Crump Comapany NameStratasys Ltd. August 8, 2019 Page 2 FirstName LastName S. Scott Crump Stratasys Ltd. August 8, 2019 Page 2 please explain why you have omitted the statement of cash flows or revise future filings to reference this financial statement. 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 Becky Chow, Staff Accountant, at (202) 551-6524 or Craig Wilson, Senior Assistant Chief Accountant, at (202) 551-3226 with any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services
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August 8, 2019
S. Scott Crump
Chairman of Executive Committee
Stratasys Ltd.
7665 Commerce Way
Eden Prairie, Minnesota 55344
Re:Stratasys Ltd
Form F-20 for the fiscal year ended December 31, 2018
Filed on March 07, 2019
File No. 001-35751
Dear Mr. Crump:
We have limited our review of your filing to the financial statements and related
disclosures 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 F-20 filed March 07, 2019
Notes to consolidated financial statements
Note 10. Commitments and Contingencies
Contingencies, page F-32
1.We note that you disclose the Patent Law-Based Claim initiated on November 23, 2017 on
page F-32, and you indicate that you reject the claims that serve as a basis for the
proceeding and intend to vigorously defend these claims. In accordance with ASC 450-
20-50, please revise future filings to clearly disclose the following information for your
loss contingencies: (1) the amount or range of reasonably possible losses in addition to the
amounts accrued or (2) a statement that the reasonably possible losses cannot be estimated
or are not material to your financial statements.
2.We note that the Company is a party to various other legal proceedings, the outcome of
which, in the opinion of management, will not have a significant adverse effect on the
financial position or profitability of the Company. With a view toward future disclosure,
FirstName LastNameS. Scott Crump
Comapany NameStratasys Ltd.
August 8, 2019 Page 2
FirstName LastName
S. Scott Crump
Stratasys Ltd.
August 8, 2019
Page 2
please explain why you have omitted the statement of cash flows or revise future filings to
reference this financial statement.
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 Becky Chow, Staff Accountant, at (202) 551-6524 or Craig Wilson,
Senior Assistant Chief Accountant, at (202) 551-3226 with any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services