SecProbe.io

May 2, 2019
Tricia Plouf
Chief Financial Officer
Trupanion, Inc.
6100 5th Avenue S
Suite 200
Seattle, Washington 98108
Re:Trupanion, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 14, 2019
File No. 001-36537
Dear Ms. Plouf:
            We have reviewed your filing 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 10 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.
Form 10-K for the Fiscal Year Ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 55
1.Your accounts receivable at year end appear to have increased at a greater rate than your
revenues.  Based on your disclosed fourth quarter revenues and a 92-day quarter, it
appears that your days sales outstanding have increased from 28.2 days at December 31,
2017 to 35.1 days at December 31, 2018.  Given that you disclose at the bottom of page
44 that most of your Subscription Business segment revenue is charged directly to either
credit cards, debit cards or through bank account automatic funds transfer, and therefore
presumably paid immediately, please tell us why your days sales outstanding have
deteriorated.  In your response tell us:
•the amount of revenues in the fourth quarters of 2017 and 2018 subject to immediate
automatic payment;

 FirstName LastNameTricia Plouf
 Comapany NameTrupanion, Inc.
 May 2, 2019 Page 2
 FirstName LastName
Tricia Plouf
Trupanion, Inc.
May 2, 2019
Page 2
•the payment terms associated with your Subscription Business and Other Business
revenue billings and whether there were any significant changes to those terms; and
•your consideration for disclosing the deterioration in your days sales outstanding and
the implication on your results of operations, financial position and liquidity.
Critical Accounting Policies and Significant Estimates
Reserve for Veterinary Invoices, page 56
2.Please describe for us the actuarial methods you utilize to estimate your reserve for
veterinary invoices including significant assumptions and changes therein and why you
believe the methods and assumptions provide a reasonable estimate.
3.Please tell us why you removed disclosure previously provided here indicating that you
did not believe that there were any reasonably likely changes in the facts or circumstances
underlying key assumptions that would result in the reserve for claims being insufficient
in an amount that would have a material impact on your reported results, financial position
or liquidity.
Notes to Consolidated Financial Statements
Note 1: Nature of Operations and Summary of Significant Accounting Policies
Revenue Recognition, page 68
4.Although you disclose that you recognize revenue pro-rata over the terms of your
customer contracts, it appears from your average pet acquisition cost disclosure on page
43 and from your deferred revenue policy note on page 67 that you recognize your sign-up
fee revenue immediately at the time of new member enrollment.  Please tell us how you
account for your sign-up fee revenue.  In your response, reference for us the authoritative
literature you rely upon to support your accounting and explain why this revenue stream
falls either under insurance accounting guidance or general revenue recognition guidance.
            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.
            You may contact Mark Brunhofer at (202) 551-3638 or Sharon Blume at (202) 551-
3474 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance