View:
April 8, 2019
Inder Singh
Chief Financial Officer
Unisys Corporation
801 Lakeview Drive, Suite 100
Blue Bell, Pennsylvania 19422
Re: Unisys Corporation
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed March 4, 2019
Form 8-K Furnished February 12, 2019
File No. 001-08729
Dear Mr. Singh:
We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.
After reviewing your response to these comments, we may have additional
comments.
Form 10-K for the Fiscal Year Ended December 31, 2018
Risk Factors, page 10
1. Considering your operations in the United Kingdom ("U.K.") as well as the
U.K. pension
plan, please tell us what consideration was given to including risk
factor disclosure for
Brexit.
Notes to Consolidated Financial Statements
Note 1 - Summary of significant accounting policies
Revenue recognition, page 38
2. Please tell us and disclose, if material, the amount of lease revenue
that is outside the
scope of ASC 606. Refer to ASC 606-10-50-4 (a).
Inder Singh
Unisys Corporation
April 8, 2019
Page 2
3. You disclose that for time and materials service contracts and
outsourcing contracts you
recognize revenue either using an output method or on a straight-line
basis. Please tell us
which methods are used for the contracts mentioned. Revise to provide
a description of
the output method used and disclose why the methods noted are a
faithful depiction of the
transfer of goods or services. Refer to ASC 606-10-50-18.
4. We note your references to "multiple element" and "multiple
deliverable" arrangements.
Please remove these references as they are not contemplated in ASC
606.
5. You disclose that "many" of your contracts have a single performance
obligation. Please
help us understand the nature of the goods and services transferred in
these contracts and
provide us with your analysis regarding how you determined that the
goods and services
in these contracts should be combined. Refer to ASC 606-10-25-19
through 22.
6. You disclose that you use the "percent discount off of list approach"
when estimating
standalone selling price. Please explain what this "approach" is, how
it is applied and for
which performance obligations you use it.
Form 8-K Furnished February 12, 2019
Exhibit 99, page 1
7. We note you disclose Adjusted EBITDA margin. Please revise throughout
your earnings
release to disclose, with equal or greater prominence, the most
directly corresponding
GAAP measure, Net Income margin. Refer to Question 102.10 of the
updated Non-
GAAP Compliance and Disclosure Interpretations. Also, revise to
reconcile Adjusted
EBITDA margin to the most directly comparable GAAP financial measure
as required by
Item 10(e)(1)(i) of Regulation S-K.
In closing, 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.
You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or
Christine
Dietz, Assistant Chief Accountant at 202-551-3408 with any questions.
Sincerely,
FirstName LastNameInder Singh
Division of
Corporation Finance
Comapany NameUnisys Corporation
Office of
Information Technologies
April 8, 2019 Page 2 and Services
FirstName LastName