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Hewlett Packard Enterprise Co Earnings Release 2020

Apr 15, 2020

30133_rns_2020-04-15_30197d4e-6fe6-476c-8b93-6895078b5eef.zip

Earnings Release

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CORRESP 1 filename1.htm html PUBLIC "-//W3C//DTD HTML 4.01 Transitional//EN" "http://www.w3.org/TR/html4/loose.dtd" Document created using Wdesk 1 Copyright 2020 Workiva Exhibit

April 15, 2020
Division of Corporation Finance United States Securities and Exchange Commission Washington, D.C. 20549
Attn: Suying Li / Angela Lumley, Office of Trade & Services

Re: Hewlett Packard Enterprise Company Item 2.02 Form 8-K dated March 3, 2020 File No. 001-37483

Dear Mses. Li and Lumley:

Hewlett Packard Enterprise Company (“HPE,” the “Company” or “we”) hereby sets forth the following information in response to the comments contained in the correspondence of the staff of the Securities and Exchange Commission (the “Staff”), dated April 10, 2020, relating to our Current Report on Form 8-K, filed March 3, 2020. We have set forth below the comment received by the Staff, as well as the Company’s response thereto.

Item 2.02 Form 8-K dated March 3, 2020

Exhibit 99.1, page 1

  1. Please revise your disclosure to provide a quantitative reconciliation for your non-GAAP gross margin and free cash flow to their most directly comparable GAAP financial measures as required by Item 10(e)(1)(i)(B) of Regulation S-K.

Response: We acknowledge the Staff’s comment regarding GAAP to non-GAAP reconciliations in connection with our earnings release furnished on Form 8-K filed March 3, 2020. We have expanded the reconciliation tables provided in connection with such earnings release to include quantitative reconciliations of non-GAAP gross margin to GAAP gross margin and free cash flow to cash flow from operations. A draft of these expanded reconciliation tables is attached hereto as Attachment A . We will include these reconciliations with respect to the three months ended January 31, 2020 in the tables accompanying our earnings release to be published with respect to the fiscal quarter ended April 30, 2020, which will be furnished on Form 8-K. We confirm that future discussions of non-GAAP gross margin and free cash flow will be accompanied by quantitative reconciliations to their most directly comparable GAAP financial measures.

Sincerely,

/s/ Tarek Robbiati

Tarek Robbiati

Chief Financial Officer

6280 America Center Drive San Jose, CA 95002 hpe.com

Attachment A

HEWLETT PACKARD ENTERPRISE COMPANY AND SUBSIDIARIES ADJUSTMENTS TO GAAP NET EARNINGS, EARNINGS FROM OPERATIONS, OPERATING PROFIT MARGIN, GROSS PROFIT, GROSS PROFIT MARGIN, CASH FLOW FROM OPERATING ACTIVITIES AND DILUTED NET EARNINGS PER SHARE (Unaudited) (In millions, except percentages and per share amounts) Three months ended January 31, 2020 Diluted net earnings per share Three months ended October 31, 2019 Diluted net earnings per share Three months ended January 31, 2019 Diluted net earnings per share
GAAP net earnings $ 333 $ 0.25 $ 480 $ 0.36 $ 177 $ 0.13
Non-GAAP adjustments:
Amortization of initial direct costs 3
Amortization of intangible assets 120 0.09 68 0.05 72 0.05
Transformation costs 89 0.07 151 0.11 78 0.06
Acquisition, disposition and other related charges (1) 42 0.03 54 0.04 63 0.04
Tax indemnification adjustments 21 0.02 (288 ) (0.22 ) (219 ) (0.16 )
Non-service net periodic benefit credit (37 ) (0.03 ) (14 ) (0.01 ) (16 ) (0.01 )
Loss from equity interests 37 0.03 38 0.03 38 0.03
Adjustments for taxes (33 ) (0.02 ) 155 0.13 397 0.28
Non-GAAP net earnings $ 575 $ 0.44 $ 644 $ 0.49 $ 590 $ 0.42
GAAP earnings from operations $ 348 $ 460 $ 456
Non-GAAP adjustments
Amortization of initial direct costs 3
Amortization of intangible assets 120 68 72
Transformation costs 89 151 78
Acquisition, disposition and other related charges (1) 42 54 63
Non-GAAP earnings from operations $ 602 $ 733 $ 669
GAAP operating profit margin 5 % 6 % 6 %
Non-GAAP adjustments 4 % 4 % 3 %
Non-GAAP operating profit margin 9 % 10 % 9 %
GAAP Net revenue $ 6,949 $ 7,215 $ 7,553
GAAP cost of sales 4,667 4,822 5,207
GAAP gross profit $ 2,282 $ 2,393 $ 2,346
Non-GAAP adjustments
Amortization of initial direct costs $ 3 $ — $ —
Acquisition, disposition and other related charges (1) 20 7
Non-GAAP gross profit $ 2,305 $ 2,400 $ 2,346
GAAP gross profit margin 32.8 % 33.2 % 31.1 %
Non-GAAP adjustments 0.4 % 0.1 % %
Non-GAAP gross profit margin 33.2 % 33.3 % 31.1 %
Net cash (used in) provided by operating activities $ (79 ) $ 1,432 $ 382
Investment in property, plant and equipment (568 ) (703 ) (729 )
Proceeds from sale of property, plant and equipment 462 149 157
Free cash flow $ (185 ) $ 878 $ (190 )

(1) Three months ended January 31, 2020 and October 31, 2019 includes Acquisition, disposition and other related charges of $20 million and $7 million, respectively, related to a non-cash inventory fair value adjustment in connection with the acquisition of Cray, Inc., which was included in Cost of Sales.