SEC Comment Letter 0000000000-24-006355 to DROPBOX, INC. (DBX)
DROPBOX, INC.
Date: June 3, 2024 · CIK: 0001467623 · Accession: 0000000000-24-006355
AI Filing Summary & Sentiment
File numbers found in text: 001-38434
Letter
United States securities and exchange commission logo June 3, 2024 Bart Volkmer General Counsel DROPBOX, INC. 1800 Owens St. San Francisco , California 94158 Re:DROPBOX, INC. Form 8-K filed May 1, 2024 File No. 001-38434 Dear Bart Volkmer: We have reviewed your filing 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 the 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 8-K filed May 1, 2024 General 1.We note the statement that you experienced a cybersecurity incident in your Form 8-K filed on May 1, 2024. Please advise us as to why you determined to file under Item 1.05 of Form 8-K given your statements that the incident has not had a material impact on your business operations, you do not believe it is likely to have a material impact on your overall business operations and you have not determined whether the incident is reasonably likely to materially impact financial condition or results of operations. 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 Geoffrey Kruczek at 202-551-3641 or Suzanne Hayes at 202-551-3675 with any other questions.
FirstName LastNameBart Volkmer Comapany NameDROPBOX, INC. June 3, 2024 Page 2 FirstName LastName Bart Volkmer DROPBOX, INC. June 3, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Manufacturing cc: Lisa Stimmell
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United States securities and exchange commission logo
June 3, 2024
Bart Volkmer
General Counsel
DROPBOX, INC.
1800 Owens St.
San Francisco , California 94158
Re:DROPBOX, INC.
Form 8-K filed May 1, 2024
File No. 001-38434
Dear Bart Volkmer:
We have reviewed your filing 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
the 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 8-K filed May 1, 2024
General
1.We note the statement that you experienced a cybersecurity incident in your Form 8-K
filed on May 1, 2024. Please advise us as to why you determined to file under Item 1.05 of
Form 8-K given your statements that the incident has not had a material impact on your
business operations, you do not believe it is likely to have a material impact on your
overall business operations and you have not determined whether the incident is
reasonably likely to materially impact financial condition or results of operations.
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 Geoffrey Kruczek at 202-551-3641 or Suzanne Hayes at 202-551-3675
with any other questions.
FirstName LastNameBart Volkmer
Comapany NameDROPBOX, INC.
June 3, 2024 Page 2
FirstName LastName
Bart Volkmer
DROPBOX, INC.
June 3, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Lisa Stimmell