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Published on April 9, 2009
Intuit Inc. | ||
2700 Coast Ave. | ||
Mountain View, CA 94043 |
April 8, 2009
Kathleen Collins
Accounting Branch Chief
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Accounting Branch Chief
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
cc: Patrick Gilmore Staff Accountant
Re: | Intuit Inc. | |||
Form 10-Q for the Quarterly Period Ended October 31, 2008 | ||||
Filed December 4, 2008 | ||||
SEC File No. 000-21180 |
Dear Ms. Collins:
We submit this letter in response to oral comments from the staff of the Securities and Exchange
Commission (the Staff), provided in a telephone conversation on March 26, 2009 among Patrick
Gilmore and Stephanie Hunsinger, members of the SEC Staff, and Jeff Hank, Vice President, Corporate
Controller of Intuit Inc. (the Company).
In the telephone conversation, the Staff requested that the Company provide further detail
regarding the assumptions used to calculate the fair value of auction rate securities. In response
to the Staffs questions, we provide the following response:
The model we used in the valuation of our auction rate securities as of October 31, 2008 and
January 31, 2009 assumed a constant yield for the estimated life of the securities as a proxy for
future interest rates. We have refined our model to calculate projected interest income using our
best estimate of interest rates in the future. Based on our revised calculations, changing this
assumption does not provide values that are materially different from the values disclosed in our
financial statements filed with our quarterly reports on Form 10-Q for the periods ended October
31, 2008 and January 31, 2009.
In future public filings with the Commission, we will use projected future interest rates in
our cash flow model and disclose this accordingly.
* * * * * * * *
We trust that you will find the foregoing responsive to the Staffs comments. If you have any
further questions or comments, please contact Jeff Hank, Vice President, Corporate Controller, at
(650) 944-3891 or Tyler Cozzens, Deputy General Counsel, at (650) 944-5574. The mailing address of
Intuit is 2700 Coast Avenue, Mountain View, CA 94043.
Very truly yours, Intuit Inc. |
||||
/s/ Jeffrey P. Hank | ||||
Jeffrey P. Hank | ||||
Vice President, Corporate Controller | ||||