August 3, 2018
Andrew Anagnost
Chief Executive Officer
Autodesk, Inc.
111 McInnis Parkway
San Rafael, California 94903
Re: Autodesk, Inc.
Form 10-K for the Fiscal Year Ended January 31, 2018
Filed March 22, 2018
Form 10-Q for the Quarterly Period Ended April 30, 2018
Filed June 8, 2018
File No. 000-14388
Dear Mr. Anagnost:
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-Q for the Quarterly Period Ended April 30, 2018
Note 3. Revenue Recognition, page 10
1. We note your disclosure that certain of your contracts contain multiple
performance
obligations that are accounted for as a single performance obligation
because they are part
of a series of distinct goods and services. Please tell us, and revise to
specify, which
arrangements contain a series of distinct goods and services. Refer to
606-10-50-12(c).
2. We note your disclosure on page 29 regarding various SaaS offerings. To
the extent that
these offerings are significant, please tell us, and revise to clarify
your revenue recognition
policy for such offerings.
Andrew Anagnost
Autodesk, Inc.
August 3, 2018
Page 2
3. We note your disclosure that you have bundled contracts with multiple
performance
obligations. Please tell us, and revise to specify, which arrangements
this disclosure refers
to. Refer to 606-10-50-12(c).
4. We note your disclosure that in your indirect channel, transfer of
control begins at the
time access to your subscription is made available electronically.
Please tell us, and revise
to clarify, if you are referring to access given to the channel
partner or to the end user.
Refer to ASC 606-10-50-17.
5. Please provide us with your analysis of how you determined that your
desktop software
and the related cloud functionality are highly interrelated and are
therefore accounted for
as a single performance obligation. Refer to 606-10-25-21(c).
6. We note your disclosure on page 12 that you do not have any material
variable
consideration. Please reconcile this statement with your disclosure on
page 11 regarding
your partner incentive program.
Note 10. Deferred Compensation
Costs to obtain a contract with a customer, page 24
7. Please help us understand the circumstances in which you pay
commissions to your
reseller partners. In addition, provide us your analysis regarding how
you determined that
these amounts should be capitalized given that resellers are your
customers.
8. You disclose that commissions earned by internal sales personnel for
contract renewals
are commensurate with those earned on the initial contract and are
amortized over the
period of benefit. Please tell us whether the period of benefit for
these commissions
exceeds the term of respective customer contract and if so, how your
policy complies with
ASC 340-40-35-1. Also refer to ASC 340-40-50-2(b).
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.
FirstName LastNameAndrew Anagnost
Division of
Corporation Finance
Comapany NameAutodesk, Inc.
Office of
Information Technologies
August 3, 2018 Page 2 and Services
FirstName LastName