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SEC Comment Letter for Asana, Inc. (ASAN) (CIK 0001477720) (ASAN) — Apr 13, 2020

Asana, Inc. (ASAN) (CIK 0001477720)
Date: April 13, 2020 · CIK: 0001477720 · Accession: 0000000000-20-003169

AI Filing Summary & Sentiment

Referenced dates: February 27, 2020

Date
March 30, 2020
Author
Office of Technology
Form
UPLOAD
Company
Asana, Inc. (ASAN) (CIK 0001477720)

Letter

March 30, 2020 Dustin Moskovitz President, Chief Executive Officer, and Chair Asana, Inc. 1550 Bryant Street, Suite 200 San Francisco, CA 94103 Re:Asana, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted March 18, 2020 CIK No. 0001477720 Dear Mr. Moskovitz: We have reviewed your amended draft offering statement and have the following comment. Our reference to a prior comment refers to a comment in our letter dated February 27, 2020. Please respond to this letter by providing the requested information and either submitting an amended draft offering statement or publicly filing your offering statement on EDGAR. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your draft offering statement or filed offering statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 1 to Draft Registration Statement on Form S-1 Prospectus Summary Benefits of Our Solution, page 6 1.Please revise to clarify that this statement is based on a customer survey you commissioned and customer case studies you conducted. Additionally, please revise here or elsewhere to provide context for the survey, including a discussion of the number of customers you surveyed, the number that responded and some type of quantification of the number that responded in a way that supports this statement.

FirstName LastNameDustin Moskovitz Comapany NameAsana, Inc. March 30, 2020 Page 2 FirstName LastName Dustin Moskovitz Asana, Inc. March 30, 2020 Page 2 You may contact Claire DeLabar, Staff Accountant, at (202) 551-3349 or Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Calise Y. Cheng, Esq.

Show Raw Text
March 30, 2020
Dustin Moskovitz
President, Chief Executive Officer, and Chair
Asana, Inc.
1550 Bryant Street, Suite 200
San Francisco, CA 94103
Re:Asana, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted March 18, 2020
CIK No. 0001477720
Dear Mr. Moskovitz:
            We have reviewed your amended draft offering statement and have the following
comment.  Our reference to a prior comment refers to a comment in our letter dated February 27,
2020.
            Please respond to this letter by providing the requested information and either submitting
an amended draft offering statement or publicly filing your offering statement on EDGAR.  If
you do not believe our comment applies to your facts and circumstances or do not believe an
amendment is appropriate, please tell us why in your response.  After reviewing any amendment
to your draft offering statement or filed offering statement and the information you provide in
response to this comment, we may have additional comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Prospectus Summary
Benefits of Our Solution, page 6
1.Please revise to clarify that this statement is based on a customer survey you
commissioned and customer case studies you conducted.  Additionally, please revise here
or elsewhere to provide context for the survey, including a discussion of the number of
customers you surveyed, the number that responded and some type of quantification of the
number that responded in a way that supports this statement.

 FirstName LastNameDustin Moskovitz
 Comapany NameAsana, Inc.
 March 30, 2020 Page 2
 FirstName LastName
Dustin Moskovitz
Asana, Inc.
March 30, 2020
Page 2
            You may contact Claire DeLabar, Staff Accountant, at (202) 551-3349 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Mitchell Austin, Staff
Attorney, at (202) 551-3574 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Calise Y. Cheng, Esq.