SEC Comment Letter for Groupon, Inc. (GRPN) (CIK 0001490281) (GRPN) — Oct 4, 2012
Groupon, Inc. (GRPN) (CIK 0001490281)
Date: Oct. 4, 2012 · CIK: 0001490281 · Accession: 0000000000-12-055049
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October 4, 2012
Via E -mail
Mr. Jason Child
Chief Financial Officer
Groupon, Inc.
600 West Chicago Avenue
Suite 620
Chicago, Illinois 60654
Re: Groupon, Inc.
Form 10 -K for the Fis cal Year Ended December 31, 2011
Filed March 30, 2012
File No. 1-35335
Dear Mr. Child:
We have completed our review of your filings. We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States. We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Robert S. Lit tlepage for
Larry Spirgel
Assistant Director