Robert Shapiro Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549
VIA EDGAR |
Re: LM Ericsson Telephone Company
Form20-F for Fiscal Year Ended December 31, 2016
Filed April 26, 2017
File No. 001-12033
Dear Mr. Shapiro:
On behalf of LM Ericsson (“Ericsson” or the “Company” or “we”), we hereby provide the following responses to the comments contained in the comment letter of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) to Ericsson, dated September 28, 2017. For ease of reference, the text of the comments in the Staff’s letter has been reproduced in bold herein.
Item 15A. Swedish Annual Report for 2016 in English (Adjusted Version)
Financials – Board of Directors’ report
Business in 2016
Financial Highlights.
Gross Margin, page 30
1. Please discuss and quantify in greater detail the reasons for theperiod-to-period changes in sales and gross margin including changes in sales price, sales volume, and service and product mix. Please also disclose if you consider the decline in sales a trend that you expect to continue or change and the reasons why. Refer to Part I, Items 5A.1 and 5.D of Form20-F.
We acknowledge the Staff’s comment and respectfully advise the Staff that Ericsson will quantify in greater detail the reasons for theperiod-to-period changes in sales and gross margin, as well as provide a discussion of any trends relating to changes in sales, in Ericsson’s Form20-F for the fiscal year ended December 31, 2017. In regard to the latter, we advise the Staff that, following the filing of Ericsson’s Form20-F for the fiscal year ended
| Telefonaktiebolaget LM Ericsson | ||||||
| SE-164 83 Stockholm | ||||||
SWEDEN
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Tel: +46 10 719 00 00
| VAT: SE556016068001
| Visiting address
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| Fax: +46 10 719 95 27 | Reg no: 556016-0680 | Torshamnsgatan 21 (Kista) | ||||
 | 2 (2) |
December 31, 2016, Ericsson began to include in its reports on Form6-K furnishing its announcements regarding its quarterly results management’s views on trends under the caption “Planning Assumptions Going Forward,” and intends to include similar disclosure in Ericsson’s Form20-F for the fiscal year ended December 31, 2017.
Business Results, Segments, page 33
2. For each segment, please discuss and quantify in greater detail the reasons for theperiod-to-period changes in sales and operating income including changes in sales price, sales volume, and service and product mix. Please also disclose if you consider the decline in sales a trend that you expect to continue or change and the reasons why. Refer to Part I, Items 5A.1 and 5.D of Form20-F.
We acknowledge the Staff’s comment and respectfully advise the Staff that Ericsson will for each segment quantify in greater detail the reasons for theperiod-to-period changes in sales and operating income, as well as provide a discussion of any trends relating to changes in sales, in Ericsson’s Form20-F for the fiscal year ended December 31, 2017. In regard to the latter, we advise the Staff that following the filing of Ericsson’s Form20-F for the fiscal year ended December 31, 2016, Ericsson began to include in its reports on Form6-K furnishing its announcements regarding its quarterly results management’s views on trends under the caption “Planning Assumptions Going Forward,” and intends to include similar disclosure on a segment basis in Ericsson’s Form20-F for the fiscal year ended December 31, 2017.
If you have additional questions, please do not hesitate to contact us.
October 27, 2017
TELEFONAKTIEBOLAGET LM ERICSSON
Sincerely,
/s/ Carl Mellander
Carl Mellander
Chief Financial Officer
| cc: | Securities and Exchange Commission | |
| Division of Corporation Finance | ||
| Ivette Leon | ||
| Carlos Pacho | ||
| Telefonaktiebolaget LM Ericsson | ||
| Nina Macpherson | ||
| Simpson Thacher & Bartlett LLP | ||
| Joshua Ford Bonnie | ||