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SEC Company Response from Groupon, Inc. (GRPN) (CIK 0001490281) (GRPN) — Jun 11, 2013

Groupon, Inc. (GRPN) (CIK 0001490281)
Date: June 11, 2013 · CIK: 0001490281 · Accession: 0001193125-13-254849

AI Filing Summary & Sentiment

Referenced dates: May 31, 2013

Date
June 11, 2013
Author
submitted
Form
CORRESP
Company
Groupon, Inc. (GRPN) (CIK 0001490281)

Letter

Division of Corporation Finance Filed February 27, 2013 Form 10-Q for the Quarter Ended March 31, 2013 Filed May 9, 2013 File No. 1-35335

Dear Mr. Spirgel:

On behalf of Groupon, Inc. (the “Company”), I am writing to follow up on my conversation with Ms. Kathryn Jacobson, Senior Staff Accountant, of the Securities and Exchange Commission. Consistent with that conversation and in order for the Company to consider and respond fully to the Staff’s comments, the Company is formally requesting an extension to respond to the Staff’s comment letter dated May 31, 2013 regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2012 and Form 10-Q for the fiscal quarter ended March 31, 2013.

Based on the above, the Company respectfully requests an extension of time until June 28, 2013 to properly respond to the Staff’s comments.

If you have any questions regarding the information contained in this letter, or need further information, please do not hesitate to call me at (312) 558-5979.

Respectfully
submitted,
/s/ Steven J. Gavin

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 Winston & Strawn LLP

35 West Wacker Drive

 Chicago, Illinois 60654

 June 11, 2013

 BY EDGAR

Mr. Larry Spirgel

 Assistant Director

 Division of Corporation Finance

U.S. Securities and Exchange Commission

 100 F
Street, NE

 Mail Stop 3720

Washington, DC 20549

Re:
Groupon, Inc.

Form 10-K for the Year Ended December 31, 2012

Filed February 27, 2013

Form 10-Q for the Quarter Ended March 31, 2013

Filed May 9, 2013

File No. 1-35335

 Dear
Mr. Spirgel:

 On behalf of Groupon, Inc. (the “Company”), I am writing to follow up on my conversation
with Ms. Kathryn Jacobson, Senior Staff Accountant, of the Securities and Exchange Commission. Consistent with that conversation and in order for the Company to consider and respond fully to the Staff’s comments, the Company is formally
requesting an extension to respond to the Staff’s comment letter dated May 31, 2013 regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2012 and Form 10-Q for the fiscal quarter ended
March 31, 2013.

 Based on the above, the Company respectfully requests an extension of time until June 28, 2013 to
properly respond to the Staff’s comments.

 If you have any questions regarding the information contained in this letter,
or need further information, please do not hesitate to call me at (312) 558-5979.

 Respectfully
submitted,

 /s/ Steven J. Gavin

Steven J. Gavin

cc:
David R. Schellhase

Dan Horwood