SEC Comment Letter 0000000000-23-005760 to Roblox Corp (RBLX) (CIK 0001315098) (RBLX)
Roblox Corp (RBLX) (CIK 0001315098)
Date: June 1, 2023 · CIK: 0001315098 · Accession: 0000000000-23-005760
AI Filing Summary & Sentiment
File numbers found in text: 001-39763
Letter
United States securities and exchange commission logo June 1, 2023 Michael Guthrie Chief Financial Officer Roblox Corporation 970 Park Place San Mateo, CA 94403 Re:Roblox Corporation Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 28, 2023 Form 10-Q for the Quarterly Period Ended March 31, 2023 Filed May 10, 2023 File No. 001-39763 Dear Michael Guthrie: We have reviewed your May 9, 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 April 21, 2023 letter. Form 10-Q for the Quarterly Period Ended March 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Operating Metrics, page 27 1.We note your response to prior comment 1 and proposed disclosures regarding average daily bookings per DAU and average daily bookings per daily unique payer. Please tell us your consideration to include these measures in your MD&A disclosures to provide further context to your discussion of bookings as they relate to users and payers.
FirstName LastNameMichael Guthrie Comapany NameRoblox Corporation June 1, 2023 Page 2 FirstName LastName Michael Guthrie Roblox Corporation June 1, 2023 Page 2 2.We note from your response to prior comment 5 that you track monthly active users (MAUs) as a measure of market penetration and you use DAU/MAU to measure product- market fit. As you state that you track this information and as it appears to be useful to an understanding of your business and how users engage with your platform, please revise to disclose such measures for each period provided. Refer to SEC Release 33-10751. You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Mark Reinstra, General Counsel
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United States securities and exchange commission logo
June 1, 2023
Michael Guthrie
Chief Financial Officer
Roblox Corporation
970 Park Place
San Mateo, CA 94403
Re:Roblox Corporation
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 28, 2023
Form 10-Q for the Quarterly Period Ended March 31, 2023
Filed May 10, 2023
File No. 001-39763
Dear Michael Guthrie:
We have reviewed your May 9, 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
April 21, 2023 letter.
Form 10-Q for the Quarterly Period Ended March 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Operating Metrics, page 27
1.We note your response to prior comment 1 and proposed disclosures regarding average
daily bookings per DAU and average daily bookings per daily unique payer. Please tell us
your consideration to include these measures in your MD&A disclosures to provide
further context to your discussion of bookings as they relate to users and payers.
FirstName LastNameMichael Guthrie
Comapany NameRoblox Corporation
June 1, 2023 Page 2
FirstName LastName
Michael Guthrie
Roblox Corporation
June 1, 2023
Page 2
2.We note from your response to prior comment 5 that you track monthly active users
(MAUs) as a measure of market penetration and you use DAU/MAU to measure product-
market fit. As you state that you track this information and as it appears to be useful to an
understanding of your business and how users engage with your platform, please revise to
disclose such measures for each period provided. Refer to SEC Release 33-10751.
You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Mark Reinstra, General Counsel