SEC Comment Letter 0000000000-23-004729 to Strategy Inc (MSTR)
Strategy Inc
Date: May 8, 2023 · CIK: 0001050446 · Accession: 0000000000-23-004729
AI Filing Summary & Sentiment
File numbers found in text: 000-24435
Letter
United States securities and exchange commission logo May 8, 2023 Andrew Kang Senior Executive VP and Chief Financial Officer Microstrategy Inc. 1840 Towers Crescent Plaza Tysons Corner, VA 22182 Re:Microstrategy Inc Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 16, 2023 File No. 000-24435 Dear Andrew Kang: We have reviewed your April 19, 2023 response to our comment letter and have the following comment. Our comment 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 these comments, we may have additional comments. Unless we note otherwise, reference to our prior comment is to our April 5, 2023 letter. Form 10-K for the year ended December 31, 2022 Notes to Consolidated Financial Statements Note 4. Digital Assets, page 88 1.We note your response to prior comment 3 and your revised disclosures in your recent Form 10-Q filing where you included the market value at quarter end of bitcoin pledged as collateral. Please also revise your financial statement footnotes disclosures to provide the dollar amount of bitcoin included in your digital asset balance sheet line item at period end that is is pledged as collateral.
FirstName LastNameAndrew Kang Comapany NameMicrostrategy Inc. May 8, 2023 Page 2 FirstName LastName Andrew Kang Microstrategy Inc. May 8, 2023 Page 2 Please contact Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jeanine Montgomery, CAO
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United States securities and exchange commission logo
May 8, 2023
Andrew Kang
Senior Executive VP and Chief Financial Officer
Microstrategy Inc.
1840 Towers Crescent Plaza
Tysons Corner, VA 22182
Re:Microstrategy Inc
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 16, 2023
File No. 000-24435
Dear Andrew Kang:
We have reviewed your April 19, 2023 response to our comment letter and have the
following comment. Our comment 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 these comments, we may have additional
comments. Unless we note otherwise, reference to our prior comment is to our April 5,
2023 letter.
Form 10-K for the year ended December 31, 2022
Notes to Consolidated Financial Statements
Note 4. Digital Assets, page 88
1.We note your response to prior comment 3 and your revised disclosures in your recent
Form 10-Q filing where you included the market value at quarter end of bitcoin pledged as
collateral. Please also revise your financial statement footnotes disclosures to provide the
dollar amount of bitcoin included in your digital asset balance sheet line item at period
end that is is pledged as collateral.
FirstName LastNameAndrew Kang
Comapany NameMicrostrategy Inc.
May 8, 2023 Page 2
FirstName LastName
Andrew Kang
Microstrategy Inc.
May 8, 2023
Page 2
Please contact Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Jeanine Montgomery, CAO