SEC Comment Letter 0000000000-24-003279 to SPS COMMERCE INC (SPSC) (CIK 0001092699) (SPSC)
SPS COMMERCE INC (SPSC) (CIK 0001092699)
Date: March 26, 2024 · CIK: 0001092699 · Accession: 0000000000-24-003279
AI Filing Summary & Sentiment
File numbers found in text: 001-34702
Letter
United States securities and exchange commission logo March 26, 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 Response dated March 14, 2024 File No. 001-34702 Dear Kimberly Nelson: We have reviewed your March 14, 2024 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 the 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 March 4, 2024 letter. 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 your response to prior comment 1. While you state that customer attrition is not a "key metric" used by management in making strategic business decisions or that you do "not necessarily need to monitor customer contract renewals," please tell us whether you otherwise calculate attrition or renewal rates internally on a regular basis. If so, provide us with a breakdown of such rates for each of the last three fiscal years so that we may better assess your response and disclosures. In addition, while you state in your response to prior comment 2 that revenue from new customers is generally not tracked and you do not believe it is possible without undue effort to disclose revenue from recently acquired business combinations, tell us how you considered disclosing the number of new customers acquired each period, both organically and from business combinations, to add
FirstName LastNameKimberly Nelson Comapany NameSPS Commerce, Inc. March 26, 2024 Page 2 FirstName LastName Kimberly Nelson SPS Commerce, Inc. March 26, 2024 Page 2 further context to your source of revenue and your ability to retain customers. In your response, provide us with the number of new customers acquired during each period presented both in total and separately from business combinations. Please contact Megan Akst at 202-551-3407 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: Brian Senger
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United States securities and exchange commission logo
March 26, 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
Response dated March 14, 2024
File No. 001-34702
Dear Kimberly Nelson:
We have reviewed your March 14, 2024 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
the 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 March 4,
2024 letter.
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 your response to prior comment 1. While you state that customer attrition is not a
"key metric" used by management in making strategic business decisions or that you do
"not necessarily need to monitor customer contract renewals," please tell us whether you
otherwise calculate attrition or renewal rates internally on a regular basis. If so, provide us
with a breakdown of such rates for each of the last three fiscal years so that we may better
assess your response and disclosures. In addition, while you state in your response to prior
comment 2 that revenue from new customers is generally not tracked and you do not
believe it is possible without undue effort to disclose revenue from recently acquired
business combinations, tell us how you considered disclosing the number of new
customers acquired each period, both organically and from business combinations, to add
FirstName LastNameKimberly Nelson
Comapany NameSPS Commerce, Inc.
March 26, 2024 Page 2
FirstName LastName
Kimberly Nelson
SPS Commerce, Inc.
March 26, 2024
Page 2
further context to your source of revenue and your ability to retain customers. In your
response, provide us with the number of new customers acquired during each period
presented both in total and separately from business combinations.
Please contact Megan Akst at 202-551-3407 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: Brian Senger