SEC Comment Letter 0000000000-24-010149 to Workday, Inc. (WDAY) (CIK 0001327811) (WDAY)
Workday, Inc. (WDAY) (CIK 0001327811)
Date: Sept. 9, 2024 · CIK: 0001327811 · Accession: 0000000000-24-010149
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File numbers found in text: 001-35680
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September 9, 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
Response dated September 4, 2024
File No. 001-35680
Dear Zane Rowe:
We have reviewed your September 4, 2024 response to our comment letter and have the
following comment.
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 our
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 August 5, 2024 letter.
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, page 37
Please address the following as it relates to your response and proposed revised
disclosures to prior comment 2.
•We note you currently disclose that gross and net retention rates exceeded 95% and
100%, respectively, for the periods presented in your recent Form 10-K and Form
10-Q filings. To the extent you intend to provide similar disclosures in future filings,
revise to ensure that the amounts provided appropriately reflect your current net
retention rates.
You state that net retention rate is calculated by taking the current period-end ARR of
your customers that you “retained" year-over-year. Clarify whether you calculate
ARR using existing customers from the corresponding period and compare that to
ARR for the current period from the same set of customers. If so, revise to clarify as •1.
September 9, 2024
Page 2
such. To the extent you do not use the same customer base for each period in your
calculation, explain further how this measure factors in customer churn.
•Tell us the amount of subscription contracts that are excluded from your calculation
of ARR. To the extent material to total subscription contracts, revise to disclose the
percentage of ARR that is excluded from such measure.
Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at 202-551-3499 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:David Bell