SEC Comment Letter 0000000000-23-007203 to Redfin Corp (RDFN) (CIK 0001382821)
Redfin Corp (RDFN) (CIK 0001382821)
Date: July 6, 2023 · CIK: 0001382821 · Accession: 0000000000-23-007203
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File numbers found in text: 001-38160
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United States securities and exchange commission logo
July 6, 2023
Chris Nielsen
Chief Financial Officer
Redfin Corporation
1099 Stewart Street, Suite 600
Seattle, WA 98101
Re:Redfin Corp
Form 10-K for the year ended December 31, 2022
Filed February 16, 2023
File No. 001-38160
Dear Chris Nielsen:
We have limited our review of your filing to the financial statements and related
disclosures 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 our comment 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 our comment, we may have additional comments.
Form 10-K for the year ended December 31, 2022
Acquired Intangible Assets and Goodwill
Goodwill, page 44
1.Please disclose whether you believe the estimated fair values of your reporting units
substantially exceed their carrying values. For any reporting units that have estimated fair
values that do not substantially exceed their carrying values, please provide useful and
meaningful information that would allow investors to better assess the probability of a
future goodwill impairment, including the following:
• Identify the reporting unit and quantify the amount of goodwill allocated to the reporting
unit.
• Disclose the percentage by which the estimated fair value exceeded carrying value as of
the date of the most recent impairment test.
• Disclose and discuss the specific critical assumptions used in your fair
value determination.
FirstName LastNameChris Nielsen
Comapany NameRedfin Corporation
July 6, 2023 Page 2
FirstName LastName
Chris Nielsen
Redfin Corporation
July 6, 2023
Page 2
• Address the degree of uncertainty associated with your key assumptions and disclose
how changes in key assumptions could impact your fair value determination.
• Describe potential events and/or changes in circumstances that could reasonably be
expected to negatively affect your key assumptions.
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.
You may contact Howard Efron at 202-551-3439 or Kristi Marrone at 202-551-3429 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Anthony Kappus