SEC Comment Letter 0000000000-23-006512 to Roblox Corp (RBLX) (CIK 0001315098) (RBLX)
Roblox Corp (RBLX) (CIK 0001315098)
Date: June 16, 2023 · CIK: 0001315098 · Accession: 0000000000-23-006512
AI Filing Summary & Sentiment
File numbers found in text: 001-39763
Letter
United States securities and exchange commission logo June 16, 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 June 8, 2023 response to our comment letter and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 1, 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.You state in your response to prior comment 2 that MAU information could be inflated by users who have multiple accounts and are therefore tracked as separate active users, which you believe may cause confusion for investors. We also note that similar circumstances may exist in the DAU measure, which you explain on page 3 where you state that DAUs are not a measure of unique individuals accessing Roblox. Please explain further why you are unable to provide MAU and DAU/MAU information along with an explanation regarding the fact that a single user may have multiple accounts, similar to what you provide for DAUs.
FirstName LastNameMichael Guthrie Comapany NameRoblox Corporation June 16, 2023 Page 2 FirstName LastName Michael Guthrie Roblox Corporation June 16, 2023 Page 2 You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any 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 16, 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 June 8, 2023 response to our comment letter and have the
following comment. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our June 1, 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.You state in your response to prior comment 2 that MAU information could be inflated by
users who have multiple accounts and are therefore tracked as separate active users, which
you believe may cause confusion for investors. We also note that similar circumstances
may exist in the DAU measure, which you explain on page 3 where you state that DAUs
are not a measure of unique individuals accessing Roblox. Please explain further why you
are unable to provide MAU and DAU/MAU information along with an explanation
regarding the fact that a single user may have multiple accounts, similar to what you
provide for DAUs.
FirstName LastNameMichael Guthrie
Comapany NameRoblox Corporation
June 16, 2023 Page 2
FirstName LastName
Michael Guthrie
Roblox Corporation
June 16, 2023
Page 2
You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Mark Reinstra, General Counsel