SEC Comment Letter 0000000000-24-009541 to Workday, Inc. (WDAY) (CIK 0001327811) (WDAY)
Workday, Inc. (WDAY) (CIK 0001327811)
Date: Aug. 20, 2024 · CIK: 0001327811 · Accession: 0000000000-24-009541
AI Filing Summary & Sentiment
File numbers found in text: 001-35680
Letter
August 20, 2024 Zane Rowe Chief Financial Officer Workday, Inc. 6110 Stoneridge Mall Road Pleasanton, CA 94588 Re:Workday, Inc. Form 10-K for the year ended January 31, 2024 File No. 001-35680 Dear Zane Rowe: 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 year ended January 31, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Revenues, page 37 1.We note that fluctuations between periods in subscription revenue was due to various factors including increases in new customers, expanded offerings to existing customers and strong customer renewals. We also note your reference to changes being due “primarily” to these factors. Where a material change is attributed to two or more factors, including any offsetting factors, revise to describe the contribution of each factor in quantified terms. Please also revise to use more definitive terminology, rather than general or vague terms such as “primarily,” to describe each contributing factor. Refer to Item 303(b) of Regulation S-K.
August 20, 2024 Page 2 2.We note your disclosure of both gross and net retention rate. Please revise to disclose information about each of these metrics, including a description and definition of each and how they are calculated. Also, tell us whether management considers these to be key performance indicators and what consideration was given to disclosing the actual retention rates for each period along with a discussion of significant fluctuations between periods. In your response, provide us with the actual gross and net retention rates for each period provided. Refer to SEC Release No. 33-10751. 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 Brittany Ebbertt at 202-551-3572 or Kathleen Collins at 202-551-3499 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc:David Bell
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August 20, 2024
Zane Rowe
Chief Financial Officer
Workday, Inc.
6110 Stoneridge Mall Road
Pleasanton, CA 94588
Re:Workday, Inc.
Form 10-K for the year ended January 31, 2024
File No. 001-35680
Dear Zane Rowe:
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 year ended January 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Revenues, page 37
1.We note that fluctuations between periods in subscription revenue was due to various
factors including increases in new customers, expanded offerings to existing customers
and strong customer renewals. We also note your reference to changes being due
“primarily” to these factors. Where a material change is attributed to two or more factors,
including any offsetting factors, revise to describe the contribution of each factor in
quantified terms. Please also revise to use more definitive terminology, rather than general
or vague terms such as “primarily,” to describe each contributing factor. Refer to Item
303(b) of Regulation S-K.
August 20, 2024
Page 2
2.We note your disclosure of both gross and net retention rate. Please revise to disclose
information about each of these metrics, including a description and definition of each and
how they are calculated. Also, tell us whether management considers these to be key
performance indicators and what consideration was given to disclosing the actual
retention rates for each period along with a discussion of significant fluctuations between
periods. In your response, provide us with the actual gross and net retention rates for each
period provided. Refer to SEC Release No. 33-10751.
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 Brittany Ebbertt at 202-551-3572 or Kathleen Collins at 202-551-3499
with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:David Bell