SEC Comment Letter for ETSY INC (ETSY) (CIK 0001370637) (ETSY) — Aug 5, 2016
ETSY INC (ETSY) (CIK 0001370637)
Date: Aug. 5, 2016 · CIK: 0001370637 · Accession: 0000000000-16-087396
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 August 5, 2016 Kristina Salen Chief Financial Officer Etsy, Inc. 55 Washington Street Suite 512 Brooklyn, NY 11201
Re: Etsy, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Response Dated August 4, 2016 File No. 001 -36911
Dear Ms. Salen :
We have reviewed your August 4, 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 5, 2016 letter .
Form 10 -K for the Fiscal Year Ended December 31, 2015
Item 8. Financial Stat ements and Supplementary Data
Note 11 – Income Taxes, page 94
1. We note your response to comment 3. Since the disclosures on page 97 that are refere nced in your response describe a deferred ta x liability and unrecognized tax benefits that are classified within “other liabilities ,” we do not believe those disclosures concerning liabilities clearly explain to your investors the assets on your balance sheet titled “Deferred tax cha rge – current ” and “Deferred tax charge – net of current portion. ”
Kristina Salen Etsy, Inc. August 5, 2016 Page 2
Please revise your tax footnote in future filings to also explain the assets you recorded related to updating your global corporate structur e.
You may contact me at (202) 551 -3737 if you have questions regarding comment s on the financial statements or any other questions.
Sincerely,
/s/ Jennifer Thompson
Show Raw Text
Mail Stop 3561 August 5, 2016 Kristina Salen Chief Financial Officer Etsy, Inc. 55 Washington Street Suite 512 Brooklyn, NY 11201 Re: Etsy, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Response Dated August 4, 2016 File No. 001 -36911 Dear Ms. Salen : We have reviewed your August 4, 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 5, 2016 letter . Form 10 -K for the Fiscal Year Ended December 31, 2015 Item 8. Financial Stat ements and Supplementary Data Note 11 – Income Taxes, page 94 1. We note your response to comment 3. Since the disclosures on page 97 that are refere nced in your response describe a deferred ta x liability and unrecognized tax benefits that are classified within “other liabilities ,” we do not believe those disclosures concerning liabilities clearly explain to your investors the assets on your balance sheet titled “Deferred tax cha rge – current ” and “Deferred tax charge – net of current portion. ” Kristina Salen Etsy, Inc. August 5, 2016 Page 2 Please revise your tax footnote in future filings to also explain the assets you recorded related to updating your global corporate structur e. You may contact me at (202) 551 -3737 if you have questions regarding comment s on the financial statements or any other questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief Office of Consumer Products