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December 17, 2015 |
VIA EDGAR AND BY HAND
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-0407
Attn: Ivan Griswold
Re: | SecureWorks Corp. |
Amendment No. 4 to Draft Registration Statement on Form S-1 |
Submitted December 7, 2015 |
CIK No. 0001468666 |
Ladies and Gentlemen:
SecureWorks Corp. (the “Company”) hereby submits its response to the Commission staff’s comment on the above-referenced submission (the “draft registration statement”) contained in the staff’s letter to the Company dated December 15, 2015. The staff’s comment is duplicated below in italicized text, and the Company’s response is set forth in plain text immediately following the comment. We also are enclosing copies of the Company’s registration statement filed on the date of this letter, which is marked to show all changes to amendment no. 4 to the draft registration statement submitted on December 7, 2015.
Condensed Combined Financial Statements
Notes to Condensed Combined Financial Statements
Note 4 – Debt
Convertible Notes, page F-38
1. | We note your expanded disclosures regarding the convertible notes. Please revise to describe the optional conversion feature as well as provide all of the applicable disclosure indicated in ASC 480-10-50-2 and paragraphs 50-10 and 50-28 of ASC 825-10-50. |
In response to the staff’s comment, the Company has revised the disclosure on pages F-38 and F-39 of the registration statement.
* * * *
Securities and Exchange Commission
December 17, 2015
Page 2
If the staff has any questions or requires additional information concerning the above matters, please contact the undersigned at (703) 610-6189 or, in my absence, Richard Parrino of our firm at (202) 637-5530.
Very truly yours,
/s/ Kevin K. Greenslade
Kevin K. Greenslade
Enclosures
cc (w/encl): | Michael R. Cote |
President and Chief Executive Officer |
SecureWorks Corp. |
Janet B. Wright |
Vice President-Corporate, Securities |
& Finance Counsel |
Dell Inc. |