SEC Comment Letter for VivoPower International PLC (VIVO) (CIK 0001681348) (VIVO) — Apr 24, 2018
VivoPower International PLC (VIVO) (CIK 0001681348)
Date: April 24, 2018 · CIK: 0001681348 · Accession: 0000000000-18-012603
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4631 April 24 , 2018 Via E -mail Mr. Carl Weatherley -White, Chief Financial Officer VivoPower International PLC 91 Wimpole Street, Marylebone London W1G 0EF United Kingdom
Re: VivoPower International PLC Form 20-F for the year ended March 31, 2017 Filed August 1, 2017 as amended on August 1, 2017 File No. 1 -37974
Dear Mr. Weatherley -White :
We have reviewed your April 3 , 2018 response to our comment letter 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 this comment within ten busine ss days by providing the requested information or advis e us as soon as poss ible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 20 , 2018 letter .
Form 20 -F for the fiscal year ended March 31, 2017
Consolidated Statement of Comprehensive Income, page F -4
1. We have read your response to our prior comment number one. We n ote your presentation of gross profit excluding the costs associated with development fees, presents a measure of gross profit that is incomplete, as it excludes costs that you are required to incur to generate revenue . As a result, it appears that your c urrent presentation does not provide your financial statement users any insight into the total cost you incurred to generate your revenue or the amount incurred for other functional activities, such as general and administrative. Accordin gly, it appears th at you should revise your financial statement presentation to report line items comprised of functional
Mr. Carl Weatherley -White VivoPower International PLC April 24 , 2018 Page 2
expenses of a similar nature and subtotals of gross profit that are complete . Please refer to paragraphs 15, 29, 85, 85A, 99, and 103 of IAS 1.
You may contact Mindy Hooker at (202) 551 -3732, Kevin Stertzel at (202) 551 -3723 or me at (202) 551 -3768 with any questions.
Sincerely,
/s/ John Cash
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Mail Stop 4631
April 24 , 2018
Via E -mail
Mr. Carl Weatherley -White, Chief Financial Officer
VivoPower International PLC
91 Wimpole Street, Marylebone
London W1G 0EF
United Kingdom
Re: VivoPower International PLC
Form 20-F for the year ended March 31, 2017
Filed August 1, 2017 as amended on August 1, 2017
File No. 1 -37974
Dear Mr. Weatherley -White :
We have reviewed your April 3 , 2018 response to our comment letter 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 this comment within ten busine ss days by providing the requested
information or advis e us as soon as poss ible when you will respond. If you do not believe our
comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our March 20 ,
2018 letter .
Form 20 -F for the fiscal year ended March 31, 2017
Consolidated Statement of Comprehensive Income, page F -4
1. We have read your response to our prior comment number one. We n ote your
presentation of gross profit excluding the costs associated with development fees,
presents a measure of gross profit that is incomplete, as it excludes costs that you are
required to incur to generate revenue . As a result, it appears that your c urrent
presentation does not provide your financial statement users any insight into the total cost
you incurred to generate your revenue or the amount incurred for other functional
activities, such as general and administrative. Accordin gly, it appears th at you should
revise your financial statement presentation to report line items comprised of functional
Mr. Carl Weatherley -White
VivoPower International PLC
April 24 , 2018
Page 2
expenses of a similar nature and subtotals of gross profit that are complete . Please refer
to paragraphs 15, 29, 85, 85A, 99, and 103 of IAS 1.
You may contact Mindy Hooker at (202) 551 -3732, Kevin Stertzel at (202) 551 -3723 or
me at (202) 551 -3768 with any questions.
Sincerely,
/s/ John Cash
John Cash
Branch Chief
Office of Manufacturing and
Construction