SEC Comment Letter 0000000000-23-011556 to PubMatic, Inc. (PUBM) (CIK 0001422930) (PUBM)
PubMatic, Inc. (PUBM) (CIK 0001422930)
Date: Oct. 23, 2023 · CIK: 0001422930 · Accession: 0000000000-23-011556
AI Filing Summary & Sentiment
File numbers found in text: 001-39748
Letter
United States securities and exchange commission logo October 23, 2023 Rajeev Goel Chief Executive Officer PubMatic, Inc. 601 Marshall Street Redwood City, CA 94063 Re:PubMatic, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Response dated October 11, 2023 File No. 001-39748 Dear Rajeev Goel: We have reviewed your October 11, 2023 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 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. Unless we note otherwise, any references to prior comments are to comments in our September 19, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 46 1.We note from your response to prior comment 1 that payments under the Vesting Agreements require continued employment with the company and are subject to forfeiture upon termination. Considering such arrangements require continued employment and the amounts will be paid in cash, it remains unclear how such charges are not a normal, recurring cash operating expenses. Accordingly, please remove these adjustments from your non-GAAP measures.
FirstName LastNameRajeev Goel Comapany NamePubMatic, Inc. October 23, 2023 Page 2 FirstName LastName Rajeev Goel PubMatic, Inc. October 23, 2023 Page 2 Please contact Megan Akst at 202-551-3407 or Christine Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
October 23, 2023
Rajeev Goel
Chief Executive Officer
PubMatic, Inc.
601 Marshall Street
Redwood City, CA 94063
Re:PubMatic, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Response dated October 11, 2023
File No. 001-39748
Dear Rajeev Goel:
We have reviewed your October 11, 2023 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 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. Unless
we note otherwise, any references to prior comments are to comments in our September 19, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 46
1.We note from your response to prior comment 1 that payments under the Vesting
Agreements require continued employment with the company and are subject to forfeiture
upon termination. Considering such arrangements require continued employment and
the amounts will be paid in cash, it remains unclear how such charges are not a normal,
recurring cash operating expenses. Accordingly, please remove these adjustments from
your non-GAAP measures.
FirstName LastNameRajeev Goel
Comapany NamePubMatic, Inc.
October 23, 2023 Page 2
FirstName LastName
Rajeev Goel
PubMatic, Inc.
October 23, 2023
Page 2
Please contact Megan Akst at 202-551-3407 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology