United States securities and exchange commission logo
March 4, 2024
Steven Weber
Chief Financial Officer
Fair Isaac Corporation
5 West Mendenhall
Suite 105
Bozeman, MT 59715
Re: Fair Isaac
Corporation
Form 10-K for the
Year Ended September 30, 2023
File No. 001-11689
Dear Steven Weber:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Year Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Annual Contract Value Bookings (ACV Bookings), page 32
1. Please revise your
disclosure to provide context to the amount of the ACV bookings that
is based on estimates
of future usage-based fees and disclose whether differences between
estimates and actual
results have been material.
Critical Accounting Policies and Estimates
Revenue Recognition, page 42
2. Regarding your revenue
recognition, please tell us why you have not disclosed how much
each estimate and/or
assumption has changed over the periods and the sensitivity of the
reported amount to the
methods, assumptions and estimates underlying its calculation.
Refer to Item 303(b)(3)
of Regulation S-K.
Steven Weber
FirstName LastNameSteven Weber
Fair Isaac Corporation
Comapany
March NameFair Isaac Corporation
4, 2024
March2 4, 2024 Page 2
Page
FirstName LastName
Item 8. Financial Statements and Supplementary Data
Capitalized Software and Research and Development Costs, page 57
3. Please tell us why costs incurred to maintain and support existing
products are included in
research and development. Refer to ASC 730-10-55.
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.
Please contact Nasreen Mohammed at 202-551-3773 or Joel Parker at
202-551-3651 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services