SEC Company Response from VivoPower International PLC (VIVO) (CIK 0001681348) (VIVO) — May 7, 2018
VivoPower International PLC (VIVO) (CIK 0001681348)
Date: May 7, 2018 · CIK: 0001681348 · Accession: 0001437749-18-008869
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 24, 2018
Letter
Office of Manufacturing and Construction United States Securities and Exchange Commission 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. Cash:
VivoPower International PLC (the “Company” or “VivoPower”) hereby submits the following responses to the comments received from the U.S. Securities and Exchange Commission Staff (“Staff”) set forth in the Staff’s letter dated April 24, 2018 (the “Comment Letter”) regarding the above-referenced filing of the Company (the “Form 20-F”). For your convenience, each Company response is preceded by the specific Staff comment in the Comment Letter to which the response relates.
Form 20-F for the fiscal year ended March 31, 2017
Consolidated Statement of Comprehensive Income, page F-4
Staff Comment No. 1:
1. We have read your response to our prior comment number one. We note 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 current 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. Accordingly, it appear that you should revise your financial statement presentation to report line items comprised of functional 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.
Response:
Your comment is noted and we will review the presentation of our expenses by functional activity in our future 20-F filings, with reference to IAS 1.
VIVOPOWER INTERNATIONAL PLC
91 Wimpole St, Marylebone, London W1G 1EF, United Kingdom
T: +44 (0)20 387 12800 | Company Number: 09978410
www.vivopower.com
Page 1
Should you have additional questions regarding the information contained herein, we would be pleased to discuss them with you.
Sincerely,
/s/ Carl Weatherley White
Show Raw Text
CORRESP 1 filename1.htm vpip20180507_corresp.htm May 7, 2018 Via E-mail Mr. John Cash Branch Chief Office of Manufacturing and Construction United States Securities and Exchange Commission Washington, D.C. 20549 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. Cash: VivoPower International PLC (the “Company” or “VivoPower”) hereby submits the following responses to the comments received from the U.S. Securities and Exchange Commission Staff (“Staff”) set forth in the Staff’s letter dated April 24, 2018 (the “Comment Letter”) regarding the above-referenced filing of the Company (the “Form 20-F”). For your convenience, each Company response is preceded by the specific Staff comment in the Comment Letter to which the response relates. Form 20-F for the fiscal year ended March 31, 2017 Consolidated Statement of Comprehensive Income, page F-4 Staff Comment No. 1: 1. We have read your response to our prior comment number one. We note 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 current 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. Accordingly, it appear that you should revise your financial statement presentation to report line items comprised of functional 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. Response: Your comment is noted and we will review the presentation of our expenses by functional activity in our future 20-F filings, with reference to IAS 1. VIVOPOWER INTERNATIONAL PLC 91 Wimpole St, Marylebone, London W1G 1EF, United Kingdom T: +44 (0)20 387 12800 | Company Number: 09978410 www.vivopower.com Page 1 Should you have additional questions regarding the information contained herein, we would be pleased to discuss them with you. Sincerely, /s/ Carl Weatherley White Chief Executive Officer VIVOPOWER INTERNATIONAL PLC 91 Wimpole St, Marylebone, London W1G 1EF, United Kingdom T: +44 (0)20 387 12800 | Company Number: 09978410 www.vivopower.com Page 2