SEC Comment Letter for Groupon, Inc. (GRPN) (CIK 0001490281) (GRPN) — Jul 22, 2013
Groupon, Inc. (GRPN) (CIK 0001490281)
Date: July 22, 2013 · CIK: 0001490281 · Accession: 0000000000-13-040002
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July 22, 2013 Via E -mail Mr. Jason E. Child Chief Financial Officer Groupon, Inc. 600 West Chicago Avenue, Suite 400 Chicago, Illinois 60654 Re: Groupon, Inc. Form 10-K for the Year Ended December 31, 2012 Filed February 27 , 2013 File No. 1-35335 Dear Mr. Child : We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action wi th respect to the company or its filing 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 to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Robert S. Littlepage for Larry Spir gel Assistant Director