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SEC Comment Letter 0000000000-25-003760 to Nutanix, Inc. (NTNX)

Nutanix, Inc.
Date: April 8, 2025 · CIK: 0001618732 · Accession: 0000000000-25-003760

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SEC Posture
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Reasoning

File numbers found in text: 001-37883

Date
April 8, 2025
Author
Division of
Form
UPLOAD
Company
Nutanix, Inc.

Letter

Re: Nutanix, Inc. Form 8-K furnished on February 26, 2025 Response dated April 3, 2025 File No. 001-37883 Dear Rukmini Sivaraman:

April 8, 2025

Rukmini Sivaraman Chief Financial Officer Nutanix, Inc. 1740 Technology Drive, Suite 150 San Jose, CA 95110

We have reviewed your April 3, 2025 response to our comment letter and have the following comment.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 21, 2025 letter.

Form 8-K furnished on February 26, 2025 Exhibit 99.1, page 7

1. We note your response to prior comment 3 and it remains unclear to us how your non- GAAP tax rate is commensurate with your non-GAAP measure of profitability. In this regard, we note that the non-GAAP tax rate was only 5% for the six months ended January 31, 2025 and only 6% for the fiscal year ended July 31, 2024. Please explain how you determined your non-GAAP tax rate and how you concluded that it was commensurate with your non-GAAP measure of profitability. Refer to Question 102.11 of the Non-GAAP C&DIs. April 8, 2025 Page 2

Please contact Melissa Kindelan at 202-551-3564 or Christine Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Technology

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 April 8, 2025

Rukmini Sivaraman
Chief Financial Officer
Nutanix, Inc.
1740 Technology Drive, Suite 150
San Jose, CA 95110

 Re: Nutanix, Inc.
 Form 8-K furnished on February 26, 2025
 Response dated April 3, 2025
 File No. 001-37883
Dear Rukmini Sivaraman:

 We have reviewed your April 3, 2025 response to our comment letter and
have the
following comment.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our March
21, 2025 letter.

Form 8-K furnished on February 26, 2025
Exhibit 99.1, page 7

1. We note your response to prior comment 3 and it remains unclear to us
how your non-
 GAAP tax rate is commensurate with your non-GAAP measure of
profitability. In this
 regard, we note that the non-GAAP tax rate was only 5% for the six
months ended
 January 31, 2025 and only 6% for the fiscal year ended July 31, 2024.
Please explain
 how you determined your non-GAAP tax rate and how you concluded that it
was
 commensurate with your non-GAAP measure of profitability. Refer to
Question
 102.11 of the Non-GAAP C&DIs.
 April 8, 2025
Page 2

 Please contact Melissa Kindelan at 202-551-3564 or Christine Dietz at
202-551-3408
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
</TEXT>
</DOCUMENT>