SEC Comment Letter 0000000000-23-008408 to TWILIO INC (TWLO) (CIK 0001447669) (TWLO)
TWILIO INC (TWLO) (CIK 0001447669)
Date: Aug. 4, 2023 · CIK: 0001447669 · Accession: 0000000000-23-008408
AI Filing Summary & Sentiment
File numbers found in text: 001-37806
Referenced dates: July 25, 2023
Letter
United States securities and exchange commission logo August 4, 2023 Aidan Viggiano Chief Financial Officer Twilio Inc. 101 Spear Street, Fifth Floor San Francisco, California 94105 Re:Twilio Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Response dated July 25, 2023 File No. 001-37806 Dear Aidan Viggiano: We have reviewed your July 25, 2023 response to our oral comment issued on July 12, 2023 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 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 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, 2021 General 1.You appear to present Non-GAAP gross profit as the measure of profit or loss for each reportable segment in the proposed disclosures in your letter dated July 25, 2023. Please tell us what measures of profit or loss at the segment level are provided to the CODM, the frequency such measures are provided to the CODM, and how they are used by the CODM. Please address all measures of segment profit or loss provided to the CODM, including those provided outside of the standard reporting package, such as during the budgeting process, meetings, or other means. If the CODM receives but does not use a measure of segment profit or loss, please tell us why. 2.If the CODM uses more than one measure of segment profit or loss in assessing segment performance and deciding how to allocate resources, please tell us how you determined which measure was required to be disclosed. See ASC 280-10-50-28.
FirstName LastNameAidan Viggiano Comapany NameTwilio Inc. August 4, 2023 Page 2 FirstName LastName Aidan Viggiano Twilio Inc. August 4, 2023 Page 2 3.In the proposed disclosures in your letter dated July 25, 2023, you reconcile your segment measure of profit to gross profit. Please revise to reconcile your segment measure of profit to consolidated income before taxes and discontinued operations in accordance with ASC 280-10-50-32(f). You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Robert Littlepage, Accounting Branch Chief at 202-551-3361 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Rezwan Pavri
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United States securities and exchange commission logo
August 4, 2023
Aidan Viggiano
Chief Financial Officer
Twilio Inc.
101 Spear Street, Fifth Floor
San Francisco, California 94105
Re:Twilio Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Response dated July 25, 2023
File No. 001-37806
Dear Aidan Viggiano:
We have reviewed your July 25, 2023 response to our oral comment issued on July 12,
2023 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 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
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, 2021
General
1.You appear to present Non-GAAP gross profit as the measure of profit or loss for each
reportable segment in the proposed disclosures in your letter dated July 25, 2023. Please
tell us what measures of profit or loss at the segment level are provided to the CODM, the
frequency such measures are provided to the CODM, and how they are used by the
CODM. Please address all measures of segment profit or loss provided to the CODM,
including those provided outside of the standard reporting package, such as during the
budgeting process, meetings, or other means. If the CODM receives but does not use a
measure of segment profit or loss, please tell us why.
2.If the CODM uses more than one measure of segment profit or loss in assessing segment
performance and deciding how to allocate resources, please tell us how you determined
which measure was required to be disclosed. See ASC 280-10-50-28.
FirstName LastNameAidan Viggiano
Comapany NameTwilio Inc.
August 4, 2023 Page 2
FirstName LastName
Aidan Viggiano
Twilio Inc.
August 4, 2023
Page 2
3.In the proposed disclosures in your letter dated July 25, 2023, you reconcile your segment
measure of profit to gross profit. Please revise to reconcile your segment measure of
profit to consolidated income before taxes and discontinued operations in accordance with
ASC 280-10-50-32(f).
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Robert
Littlepage, Accounting Branch Chief at 202-551-3361 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Rezwan Pavri