SEC Comment Letter 0000000000-23-003508 to LEGALZOOM.COM, INC. (LZ) (CIK 0001286139) (LZ)
LEGALZOOM.COM, INC. (LZ) (CIK 0001286139)
Date: April 7, 2023 · CIK: 0001286139 · Accession: 0000000000-23-003508
AI Filing Summary & Sentiment
File numbers found in text: 001-35618
Letter
United States securities and exchange commission logo April 7, 2023 Noel Watson Chief Financial Officer Legalzoom.com, Inc. 101 N. Brand Boulevard 11th Floor Glendale, CA 91203 Re:Legalzoom.com, Inc. Form 10-K for the year ended December 31, 2022 File No. 001-35618 Dear Noel Watson: We have reviewed your April 5, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply 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, our references to prior comments are to comments in our March 22, 2023 letter. Form 10-K for the Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 38 1.We note from your response to prior comment 1 that you believe the number of subscription units and average revenue per subscription (ARPU) are the most meaningful measures for understanding your overall subscription business, including the ongoing relationships with your customers. Please explain further how these measures provide support for the retention and growth of your existing customer base. In your response, provide us with a breakdown of subscriptions lost and new subscriptions obtained during fiscal 2022. Also, tell us how ARPU was impacted by existing customer product mix. In addition, tell us and revise to disclose the percentage or dollar amount of subscription revenue growth from new versus existing customers.
FirstName LastNameNoel Watson Comapany NameLegalzoom.com, Inc. April 7, 2023 Page 2 FirstName LastName Noel Watson Legalzoom.com, Inc. April 7, 2023 Page 2 You may contact Brittany Ebbertt, Senior Staff Accountant, at (202) 551-3572 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Thomas Hopkins
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United States securities and exchange commission logo
April 7, 2023
Noel Watson
Chief Financial Officer
Legalzoom.com, Inc.
101 N. Brand Boulevard
11th Floor
Glendale, CA 91203
Re:Legalzoom.com, Inc.
Form 10-K for the year ended December 31, 2022
File No. 001-35618
Dear Noel Watson:
We have reviewed your April 5, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments 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
comments apply 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, our references to prior comments are to comments in our
March 22, 2023 letter.
Form 10-K for the Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 38
1.We note from your response to prior comment 1 that you believe the number of
subscription units and average revenue per subscription (ARPU) are the most meaningful
measures for understanding your overall subscription business, including the ongoing
relationships with your customers. Please explain further how these measures provide
support for the retention and growth of your existing customer base. In your response,
provide us with a breakdown of subscriptions lost and new subscriptions obtained during
fiscal 2022. Also, tell us how ARPU was impacted by existing customer product mix. In
addition, tell us and revise to disclose the percentage or dollar amount of subscription
revenue growth from new versus existing customers.
FirstName LastNameNoel Watson
Comapany NameLegalzoom.com, Inc.
April 7, 2023 Page 2
FirstName LastName
Noel Watson
Legalzoom.com, Inc.
April 7, 2023
Page 2
You may contact Brittany Ebbertt, Senior Staff Accountant, at (202) 551-3572 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Thomas Hopkins