SEC Comment Letter for Science Applications International Corp (SAIC) (CIK 0001571123) (SAIC) — Jun 28, 2013
Science Applications International Corp (SAIC) (CIK 0001571123)
Date: June 28, 2013 · CIK: 0001571123 · Accession: 0000000000-13-035615
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 21, 2013
Letter
June 28 , 2013 Via E -Mail Raymond Veldman VP, Assistant General Counsel SAIC Gemini, Inc. 1710 SAIC Drive McLean, VA 22102
Re: SAIC Gemini , Inc. Amendment No. 2 to Form 10 Filed June 14, 201 3 File No. 00 1-35832
Dear Mr. Veldman :
We have reviewed your letter dated June 14 , 2013 in connection with the above - referenced filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comme nt applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have addition al comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated May 21, 2013.
Notes to Combined Financial Statements
Note 1. Summary of Significant Accounting Policies
Principles of Combination and Basis of Pre sentation, page F -7
1. You state in your response to prior comment 4 that the determination of which components to transfer to New SAIC was based on an assessment of the nature of the work performed and the markets served by each operation. Please provide u s with a breakdown of the various discrete business operations that were included in Parent’s Defense Solutions Group; identify which operations were transferred to New SAIC and which remained with Parent and include the revenues and operating income for e ach. In addition, please describe the nature of the work performed and the markets serviced for each discrete business operation.
Raymond Veldman SAIC Gemini , Inc. June 28, 2013 Page 2
You may contact Laura Veator , Staff Accountant , at (202) 551 -3716 or Kathleen Collins , Accounting Branch Chief, at (202) 5 51-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Luna Bloom, Staff Attorney , at (202) 551-3194 with any other questions. Should you require further assistance, you may contact me, at (202) 551-3462.
Sincerely,
/s/ Mark P. Shuman
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June 28 , 2013 Via E -Mail Raymond Veldman VP, Assistant General Counsel SAIC Gemini, Inc. 1710 SAIC Drive McLean, VA 22102 Re: SAIC Gemini , Inc. Amendment No. 2 to Form 10 Filed June 14, 201 3 File No. 00 1-35832 Dear Mr. Veldman : We have reviewed your letter dated June 14 , 2013 in connection with the above - referenced filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comme nt applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have addition al comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated May 21, 2013. Notes to Combined Financial Statements Note 1. Summary of Significant Accounting Policies Principles of Combination and Basis of Pre sentation, page F -7 1. You state in your response to prior comment 4 that the determination of which components to transfer to New SAIC was based on an assessment of the nature of the work performed and the markets served by each operation. Please provide u s with a breakdown of the various discrete business operations that were included in Parent’s Defense Solutions Group; identify which operations were transferred to New SAIC and which remained with Parent and include the revenues and operating income for e ach. In addition, please describe the nature of the work performed and the markets serviced for each discrete business operation. Raymond Veldman SAIC Gemini , Inc. June 28, 2013 Page 2 You may contact Laura Veator , Staff Accountant , at (202) 551 -3716 or Kathleen Collins , Accounting Branch Chief, at (202) 5 51-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Luna Bloom, Staff Attorney , at (202) 551-3194 with any other questions. Should you require further assistance, you may contact me, at (202) 551-3462. Sincerely, /s/ Mark P. Shuman Mark P. Shuman Branch Chief – Legal cc: Via E -Mail Paul Greiner