SEC Comment Letter for Strategy (MSTR) — Dec 3, 2021
Strategy Inc
Date: Dec. 3, 2021 · CIK: 0001050446 · Accession: 0000000000-21-014605
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-24435
Letter
United States securities and exchange commission logo December 3, 2021 Phong Le President & Chief Financial Officer Microstrategy Incorporated 1850 Towers Crescent Plaza Tysons Corner, VA 22182 Re:Microstrategy Incorporated Form 10-K for Fiscal Year Ended December 31, 2020 Filed February 12, 2021 Form 10-Q for the Quarter Ended September 30, 2021 Filed October 22, 2021 File No. 000-24435 Dear Mr. Le: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. References to prior comments refer to comments in our October 7, 2021 letter. Form 10-Q for the Quarterly Period Ended September 30, 2021 Non-GAAP Financial Measures, page 29 1.We note your response to prior comment 5 and we object to your adjustment for bitcoin impairment charges in your non-GAAP measures. Please revise to remove this adjustment in future filings. Refer to Rule 100 of Regulation G. 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.
FirstName LastNamePhong Le Comapany NameMicrostrategy Incorporated December 3, 2021 Page 2 FirstName LastName Phong Le Microstrategy Incorporated December 3, 2021 Page 2
You may contact Rebekah Lindsey, Senior Staff Accountant at (202) 551-3303 or Kathleen Collins, Accounting Branch Chief at (202) 551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Alexandra Barone, Staff Attorney at (202) 551-8816 or Larry Spirgel at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
December 3, 2021
Phong Le
President & Chief Financial Officer
Microstrategy Incorporated
1850 Towers Crescent Plaza
Tysons Corner, VA 22182
Re:Microstrategy Incorporated
Form 10-K for Fiscal Year Ended December 31, 2020
Filed February 12, 2021
Form 10-Q for the Quarter Ended September 30, 2021
Filed October 22, 2021
File No. 000-24435
Dear Mr. Le:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. References to prior comments refer to comments in our October 7, 2021 letter.
Form 10-Q for the Quarterly Period Ended September 30, 2021
Non-GAAP Financial Measures, page 29
1.We note your response to prior comment 5 and we object to your adjustment for bitcoin
impairment charges in your non-GAAP measures. Please revise to remove this
adjustment in future filings. Refer to Rule 100 of Regulation G.
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.
FirstName LastNamePhong Le
Comapany NameMicrostrategy Incorporated
December 3, 2021 Page 2
FirstName LastName
Phong Le
Microstrategy Incorporated
December 3, 2021
Page 2
You may contact Rebekah Lindsey, Senior Staff Accountant at (202) 551-3303 or
Kathleen Collins, Accounting Branch Chief at (202) 551-3499 if you have questions regarding
comments on the financial statements and related matters. Please contact Alexandra Barone,
Staff Attorney at (202) 551-8816 or Larry Spirgel at (202) 551-3815 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology