SEC Comment Letter 0000000000-23-013738 to MANHATTAN ASSOCIATES INC (MANH) (CIK 0001056696) (MANH)
MANHATTAN ASSOCIATES INC (MANH) (CIK 0001056696)
Date: Dec. 15, 2023 · CIK: 0001056696 · Accession: 0000000000-23-013738
AI Filing Summary & Sentiment
File numbers found in text: 000-23999
Letter
United States securities and exchange commission logo December 15, 2023 Dennis Story Chief Financial Officer Manhattan Associates, Inc. 2300 Windy Ridge Parkway, Tenth Floor Atlanta, Georgia 30339 Re:Manhattan Associates, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Response dated December 12, 2023 File No. 000-23999 Dear Dennis Story : We have reviewed your December 12, 2023 response to our comment letter and have the following comments. 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. Unless we note otherwise, any references to prior comments are to comments in our November 30, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Revenue, page 28 1.We note your response to prior comment 2 and acknowledge the disclosure on page 24. While that disclosure indicates the mix of new to existing customers for cloud subscriptions and software license for sales in 2022, it is not clear what comprises the year over year growth in cloud subscription revenue. Therefore, as previously requested, please tell us and revise to disclose the amount or percentage of the increase in cloud subscription revenue attributable to new versus existing customers including those that are migrating from on-premise offerings to cloud offerings, in order to provide better context to your results of operations discussion.
FirstName LastNameDennis Story Comapany NameManhattan Associates, Inc. December 15, 2023 Page 2 FirstName LastName Dennis Story Manhattan Associates, Inc. December 15, 2023 Page 2 2.You indicate in your response to prior comment 2 that you will disclose in future filings the percentage of professional services revenue that relates to cloud subscriptions, which was approximately 25% in 2020 and over 50% in 2022. Please tell us and revise to disclose the actual percentages for fiscal 2021 and 2022, and explain the types of professional services that comprise the remaining amounts. Further, as previously requested, in order to better explain the year over year growth in service revenue, tell us and revise to disclose the amount or percentage of the increase attributable to new versus existing customers. Please contact Chen Chen at 202-551-7351 or Melissa Kindelan at 202-551-3564 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Linda Pinne
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United States securities and exchange commission logo
December 15, 2023
Dennis Story
Chief Financial Officer
Manhattan Associates, Inc.
2300 Windy Ridge Parkway, Tenth Floor
Atlanta, Georgia 30339
Re:Manhattan Associates, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Response dated December 12, 2023
File No. 000-23999
Dear Dennis Story :
We have reviewed your December 12, 2023 response to our comment letter and have the
following comments.
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. Unless
we note otherwise, any references to prior comments are to comments in our November 30,
2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Revenue, page 28
1.We note your response to prior comment 2 and acknowledge the disclosure on page 24.
While that disclosure indicates the mix of new to existing customers for cloud
subscriptions and software license for sales in 2022, it is not clear what comprises the year
over year growth in cloud subscription revenue. Therefore, as previously requested, please
tell us and revise to disclose the amount or percentage of the increase in cloud
subscription revenue attributable to new versus existing customers including those that are
migrating from on-premise offerings to cloud offerings, in order to provide better context
to your results of operations discussion.
FirstName LastNameDennis Story
Comapany NameManhattan Associates, Inc.
December 15, 2023 Page 2
FirstName LastName
Dennis Story
Manhattan Associates, Inc.
December 15, 2023
Page 2
2.You indicate in your response to prior comment 2 that you will disclose in future filings
the percentage of professional services revenue that relates to cloud subscriptions, which
was approximately 25% in 2020 and over 50% in 2022. Please tell us and revise to
disclose the actual percentages for fiscal 2021 and 2022, and explain the types of
professional services that comprise the remaining amounts. Further, as previously
requested, in order to better explain the year over year growth in service revenue, tell us
and revise to disclose the amount or percentage of the increase attributable to new versus
existing customers.
Please contact Chen Chen at 202-551-7351 or Melissa Kindelan at 202-551-3564 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Linda Pinne