SEC Comment Letter for Hewlett Packard Enterprise Co (HPE, HPE-PC) (CIK 0001645590) (HPE) — Apr 10, 2020
Hewlett Packard Enterprise Co (HPE, HPE-PC) (CIK 0001645590)
Date: April 10, 2020 · CIK: 0001645590 · Accession: 0000000000-20-003117
AI Filing Summary & Sentiment
File numbers found in text: 001-37483
Letter
April 10, 2020 Tarek Robbiati Chief Financial Officer Hewlett Packard Enterprise Company 6280 America Center Drive San Jose, CA 95002 Re:Hewlett Packard Enterprise Company Form 10-K for Fiscal Year Ended October 31, 2019 Filed December 13, 2019 Item 2.02 Form 8-K dated March 3, 2020 File No. 001-37483 Dear Mr. Robbiati: We have reviewed your filings and 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 the comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to our comment, we may have additional comments. Item 2.02 Form 8-K dated March 3, 2020 Exhibit 99.1, page 1 1.Please revise your disclosure to provide a quantitative reconciliation for your non-GAAP gross margin and free cash flow to their most directly comparable GAAP financial measures as required by Item 10(e)(1)(i)(B) of Regulation S-K. 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.
FirstName LastNameTarek Robbiati Comapany NameHewlett Packard Enterprise Company April 10, 2020 Page 2 FirstName LastName Tarek Robbiati Hewlett Packard Enterprise Company April 10, 2020 Page 2 You may contact Suying Li at (202) 551-3335 or Angela Lumley at (202) 551-3398 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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April 10, 2020
Tarek Robbiati
Chief Financial Officer
Hewlett Packard Enterprise Company
6280 America Center Drive
San Jose, CA 95002
Re:Hewlett Packard Enterprise Company
Form 10-K for Fiscal Year Ended October 31, 2019
Filed December 13, 2019
Item 2.02 Form 8-K dated March 3, 2020
File No. 001-37483
Dear Mr. Robbiati:
We have reviewed your filings and 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 the comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to our comment, we may have additional comments.
Item 2.02 Form 8-K dated March 3, 2020
Exhibit 99.1, page 1
1.Please revise your disclosure to provide a quantitative reconciliation for your non-GAAP
gross margin and free cash flow to their most directly comparable GAAP financial
measures as required by Item 10(e)(1)(i)(B) of Regulation S-K.
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.
FirstName LastNameTarek Robbiati
Comapany NameHewlett Packard Enterprise Company
April 10, 2020 Page 2
FirstName LastName
Tarek Robbiati
Hewlett Packard Enterprise Company
April 10, 2020
Page 2
You may contact Suying Li at (202) 551-3335 or Angela Lumley at (202) 551-3398 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services