SEC Comment Letter for Groupon, Inc. (GRPN) (CIK 0001490281) (GRPN) — Aug 8, 2014
Groupon, Inc. (GRPN) (CIK 0001490281)
Date: Aug. 8, 2014 · CIK: 0001490281 · Accession: 0000000000-14-040195
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August 7 , 2014
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, 2013
Filed February 2 1, 2014
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 per sons 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 Spirgel
Assistant Director