SecProbe.io

October 28, 2024
Fawwad Qureshi
Chief Financial Officer
Trupanion, Inc.
6100 4th Avenue S, Suite 200
Seattle, WA 98108
Re:Trupanion, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-36537
Dear Fawwad Qureshi:
            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 Fiscal Year Ended December 31, 2023
Revenue, page 46
We note your disclosure on page 45 describing your revenue streams, including
subscription fees, writing policies on behalf of third parties, and insurance software
solutions. We also note your disclosures elsewhere in the filing that reference
revenues, such as but not limited to commissions (page 40), gross underwriting
premiums (page 40), and sign-up fees (page 45). To help investors better understand
your results of operation and the underlying reasons for material changes in
quantitative and qualitative terms, please revise your future filings to address the
items below. See Item 303 of Regulation S-K.
•Enhance your discussion of revenues to better define your different revenue
streams. For example, define “subscription fees” and “premiums,” distinguishing
between the two, if applicable, and explain all key revenue streams for each
segments’ business.
Where applicable, provide additional details regarding material revenue drivers
for the periods presented and the business(es) to which these apply. For example, •1.

October 28, 2024
Page 2
if commissions and premiums are material contributors to subscription and / or
other business revenues, separately quantify and discuss trends for these items.
Note 10. Reserve for Veterinary Invoices, page 80
2.We note your disclosures on page 81 that period-over-period favorable and
unfavorable development for the subscription and other business segments is
attributable to ongoing analysis of recent payment trends. In future filings, please
enhance your disclosures to include more detail on recent payment trends, and to
provide more detailed discussion, with quantification, of period-over-period changes
and trends in claim severity, frequency, average settlement time or other underlying
drivers.
3.We note your inclusion of “Non-cash expenses” in your reserve roll-forwards on page
81. In future filings, please provide a definition and explanation of what these
amounts represent.
Note 15. Segments, page 88
4.We note your disclosure that the Company has two aggregated reporting segments
and, further, that the subscription business segment consists of products that have
similar target margin profiles. Please clarify for us if the Company has
multiple operating segments that aggregate into the two reportable segments and, if
so, provide us with a summary of the Company's identified operating segments. To
the extent that the Company is aggregating or combining multiple operating segments
in determining your reportable segments pursuant to ASC 280-10-50-10 through 50-
13, provide us with your aggregation analysis. In your analysis, please compare and
contrast the similarity of the economic characteristics between the aggregated
operating segments, and address each of the areas listed in ASC 280-10-50-11a to
11e.

            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 Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance