SEC Comment Letter 0000000000-24-002428 to SPS COMMERCE INC (SPSC) (CIK 0001092699) (SPSC)
SPS COMMERCE INC (SPSC) (CIK 0001092699)
Date: March 4, 2024 · CIK: 0001092699 · Accession: 0000000000-24-002428
AI Filing Summary & Sentiment
File numbers found in text: 001-34702
Letter
United States securities and exchange commission logo March 4, 2024 Kimberly Nelson Chief Financial Officer SPS Commerce, Inc. 333 South Seventh Street, Suite 1000 Minneapolis, MN 55402 Re:SPS Commerce, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-34702 Dear Kimberly Nelson: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the Fiscal Year Ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Metrics and Non-GAAP Financial Measures, page 28 1.We note you disclose on page 12 that in order to increase your revenue and achieve and maintain profitability you must sell additional products to existing customers and your customers must increase their use of products. You also disclose that you do not have long-term contracts with most of your recurring customers and therefore the lack of success in maintaining or improving forecasted renewal rates will have an adverse effect on revenue and financial results. Please tell us what measures or metrics management uses to monitor customer retention and renewals, if any, and revise to provide a quantified discussion of such measures for each period presented. Refer to SEC Release No. 33- 10751.
FirstName LastNameKimberly Nelson Comapany NameSPS Commerce, Inc. March 4, 2024 Page 2 FirstName LastName Kimberly Nelson SPS Commerce, Inc. March 4, 2024 Page 2 Year Ended December 31, 2023 compared to year ended December 31, 2022, page 30 2.You disclose that the increase in revenue resulted, in part, from continued business growth and business acquisitions. Please tell us and revise to disclose the amount or percentage of such increase from new customers versus existing customers as well as from business acquisitions, to provide additional context to your revenue growth as well as the extent to which your various business acquisitions have impacted such growth. Refer to Item 303(b) of Regulation S-K and Section III.B.1. of SEC Release No. 33-8350. 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 Megan Akst at 202-551-3407 or Melissa Kindelan at 202-551-3564 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Brian Senger
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United States securities and exchange commission logo
March 4, 2024
Kimberly Nelson
Chief Financial Officer
SPS Commerce, Inc.
333 South Seventh Street, Suite 1000
Minneapolis, MN 55402
Re:SPS Commerce, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-34702
Dear Kimberly Nelson:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Metrics and Non-GAAP Financial Measures, page 28
1.We note you disclose on page 12 that in order to increase your revenue and achieve and
maintain profitability you must sell additional products to existing customers and your
customers must increase their use of products. You also disclose that you do not have
long-term contracts with most of your recurring customers and therefore the lack of
success in maintaining or improving forecasted renewal rates will have an adverse effect
on revenue and financial results. Please tell us what measures or metrics management uses
to monitor customer retention and renewals, if any, and revise to provide a quantified
discussion of such measures for each period presented. Refer to SEC Release No. 33-
10751.
FirstName LastNameKimberly Nelson
Comapany NameSPS Commerce, Inc.
March 4, 2024 Page 2
FirstName LastName
Kimberly Nelson
SPS Commerce, Inc.
March 4, 2024
Page 2
Year Ended December 31, 2023 compared to year ended December 31, 2022, page 30
2.You disclose that the increase in revenue resulted, in part, from continued business growth
and business acquisitions. Please tell us and revise to disclose the amount or percentage of
such increase from new customers versus existing customers as well as from business
acquisitions, to provide additional context to your revenue growth as well as the extent to
which your various business acquisitions have impacted such growth. Refer to Item
303(b) of Regulation S-K and Section III.B.1. of SEC Release No. 33-8350.
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 Megan Akst at 202-551-3407 or Melissa Kindelan at 202-551-3564 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Brian Senger