SEC Comment Letter for Hewlett Packard Enterprise Co (HPE, HPE-PC) (CIK 0001645590) (HPE) — Oct 5, 2015
Hewlett Packard Enterprise Co (HPE, HPE-PC) (CIK 0001645590)
Date: Oct. 5, 2015 · CIK: 0001645590 · Accession: 0000000000-15-048422
AI Filing Summary & Sentiment
Letter
Mail Stop 4561 October 2, 2015 Margaret C. Whitman, Chief Executive Officer Hewlett Packard Enterprise Company 3000 Hanover Street Palo Alto, California, 94304
Re: Hewlett Packard Enterprise Company Amendment No. 4 to Form 10 Filed September 28, 2015 File No. 001 - 37483
Dear Ms. Whitman:
We have reviewed your amendment 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 this l etter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After re viewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comm ents are to comments in our September 22 , 2015 lette r.
Unaudited Pro Forma Combined Financial Statements, page 41
1. We n ote your disclosure that debt issuance costs are expected to be amortized over 5.1 to 5.5 years, based upon the weighted average term of HP Co’s outstanding long -term debt securities, and that you have assumed an interest rate of 3.67% and 3.57% based upon the weighted average interest rate of HP Co.’s long -term securities. Clarify your basis for assuming the term and interest rates of HP Co.’s d ebt in your pro forma adjustments. Please disclose the actual term and interest rates of your debt arrangement, once finalized, and revise your adjustments accordingly.
Margaret C. Whitman Hewlett Packard Enterprise Company October 2, 2015 Page 2
Liquidity and Capital Resources, page 80
2. Please provide quantitative disclosure of the expected impact of your new debt arrangement on your cash flows and contractual obligations. Please also clarify the expected impact of this arrangement on your ability to pay dividends in the future.
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 regarding comments on the financial statements and related matters. Please contact Ivan Griswold, Attorney -Adviser, at (202) 551 -3853 or me at (202) 551 -3487 with any other questions.
Sincerely,
/s/ Barbara C. Jacobs
Show Raw Text
Mail Stop 4561
October 2, 2015
Margaret C. Whitman, Chief Executive Officer
Hewlett Packard Enterprise Company
3000 Hanover Street
Palo Alto, California, 94304
Re: Hewlett Packard Enterprise Company
Amendment No. 4 to Form 10
Filed September 28, 2015
File No. 001 - 37483
Dear Ms. Whitman:
We have reviewed your amendment 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 this l etter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After re viewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comm ents are to comments in our September 22 , 2015 lette r.
Unaudited Pro Forma Combined Financial Statements, page 41
1. We n ote your disclosure that debt issuance costs are expected to be amortized over 5.1 to
5.5 years, based upon the weighted average term of HP Co’s outstanding long -term debt
securities, and that you have assumed an interest rate of 3.67% and 3.57% based upon the
weighted average interest rate of HP Co.’s long -term securities. Clarify your basis for
assuming the term and interest rates of HP Co.’s d ebt in your pro forma adjustments.
Please disclose the actual term and interest rates of your debt arrangement, once
finalized, and revise your adjustments accordingly.
Margaret C. Whitman
Hewlett Packard Enterprise Company
October 2, 2015
Page 2
Liquidity and Capital Resources, page 80
2. Please provide quantitative disclosure of the expected impact of your new debt
arrangement on your cash flows and contractual obligations. Please also clarify the
expected impact of this arrangement on your ability to pay dividends in the future.
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 regarding comments on the
financial statements and related matters. Please contact Ivan Griswold, Attorney -Adviser, at
(202) 551 -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
cc: Benjamin M. Roth, Esq.
Wachtell, Lipton, Rosen & Katz