April 28, 2006
Kathleen Collins
Accounting Branch Chief
Division of Corporate Finance
Securities and Exchange Commissions
Division of Corporate Finance
100 F Street, N.E.
Washington D.C. 20549
RE: SEC Comment Letter Dated April 25, 2006
Dear Ms. Collins:
This letter responds to the comments included in your letter dated April 25, 2006, regarding Novell, Inc.'s Form 10-K for the fiscal year ended October 31, 2005 and the Forms 8-K filed December 1, 2005 and March 2, 2006.
Form 10-K For the Fiscal Year Ended October 31, 2005
Consolidated Statements of Operations, page 51
1. | We note the Company recorded a gain on settlement of potential litigation of approximately $448 million as a credit to operating expenses. Tell us the basis for recording litigation settlement within operating expenses. Further explain the basis for recording the settlement all in one year (i.e. are there any contingencies or future performance required by the Company relating to this settlement). |
Novell Response |
If you have any further comments or would like to discuss any of the responses above, please contact us at your convenience.
Sincerely yours,
By /s/ Joseph S. Tibbetts, Jr.
Joseph S. Tibbetts, Jr.
Senior Vice President and Chief Financial Officer
Novell, Inc.
781-464-8168