09 February 2017 |
Deere & Company Law Department One John Deere Place, Moline, IL 61265 USA Phone: 309-765-5161 Fax (309) 749-0085 Email: DaviesToddE@JohnDeere.com
Todd E. Davies Corporate Secretary & Associate General Counsel |
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 3030
Washington, D.C. 20549
Attention: Martin James
Senior Assistant Chief Accountant
Re: | Deere & Company |
| Form 10-K for the Fiscal Year Ended October 31, 2016 |
| Filed December 19, 2016 |
| File No. 1-04121 |
Dear Mr. James:
Set forth below is the response of Deere & Company, a Delaware corporation (the “Company”), to the comment from the Staff of the Division of Corporation Finance of the Securities and Exchange Commission, dated February 2, 2017, related to the Company’s Form 10-K for the fiscal year ended October 31, 2016. The numbered paragraph below sets forth the comment, followed by the Company’s response to the comment.
1. We note that although your fiscal year ends on the last Sunday in the reporting period, you present consolidated financial statements as of and for the periods ended October 31, 2016, 2015 and 2014 for ease of presentation. Please revise future filings to present your financial statements as of the actual fiscal year-end and to similarly reflect the actual dates where applicable throughout the 10-K.
Response: In future filings on Forms 10-Q, 10-K and other SEC filings with Company financial statements, the financial statements will reflect the actual fiscal period end, and such filings will similarly reflect the actual dates for each fiscal period end where applicable throughout each filing.
Should you have any questions or comments concerning this response to your comment letter, please contact me at (309) 765-5161.
Sincerely, |
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/s/ Todd E. Davies |
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Todd E. Davies |
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Corporate Secretary |
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