SEC Comment Letter for Hewlett Packard Enterprise Co (HPE, HPE-PC) (CIK 0001645590) (HPE) — Sep 22, 2015
Hewlett Packard Enterprise Co (HPE, HPE-PC) (CIK 0001645590)
Date: Sept. 22, 2015 · CIK: 0001645590 · Accession: 0000000000-15-046579
AI Filing Summary & Sentiment
Referenced dates: June 9, 2015
Show Raw Text
September 2, 2015 Mail S top 4561 Margaret C. Whitman, Chief Executive Officer Hewlett Packard Enterprise Company 3000 Hanover Street Palo Alto, California, 94304 Re: Hewlett Packard Enterprise Company Amendment No. 1 to Form 10 Filed August 10, 2015 File No. 001 -37483 Dear Ms. Whitman: We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment 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 registration statement and the information you provide in re sponse to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 28, 2015 letter. Management’s Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies and Estimates Goodwill, page 58 1. We note your response to prior comment 24 and your response to prior comment 1 from your letter dated June 9, 2015 relating to Hewlett Packard Company’s Form 10 -K for the fiscal year ended Octo ber 31, 2014. However, based on our telephone call with the company’s representatives on August 26, 2015, we understand that the EG segment manager reviews operating results information, including gross margins, for the business units included within the EG segment. Accordingly, for those business units it appears that discrete financial information is available that is reviewed by the segment manager. The business units also appear to be businesses as defined in ASC 805-10-55-4 through 55-9. If so, it app ears that the business units within the EG segment represent components that are reporting units, as defined in ASC 350 -20-35-34. Please clarify why you do not believe the business units represent components that are reporting units as defined by Margaret C. Whitman Hewlett Packard Enterprise Company September 2, 2015 Page 2 ASC 350 -20-35-34 and ASC 350 -20-55-1 to 5. Please also provide us with the reporting packages for the quarterly periods ended October 31, 2013 and January 31, 2014 that the EG segment manager reviewed in assessing operating results for the segment and each of the b usiness units discussed in the August 26, 2015 telephone call . If not otherwise evident, please quantify the corporate allocations included in the EG segment results that are not included in the business unit results. Also please describe the types of the corporate costs allocated and which types constitute the significant portion of that allocation. You may contact Amanda Kim, Staff Accountant, at (202) 551 -3241 or Laura Veator, Senior Staff Accountant, at (202) 551 -3716, if you have questions reg arding comments on the financial statements and related matters. Please contact Ivan Griswold, Attorney -Adviser, at (202) 55 1-3853 or me at (202) 551 -3487 with any other questions. Sincerely, /s/ Barbara C. Jacobs Barbara C. Jacobs Assistant Director Office of Information Technologies and Services