SEC Comment Letter 0000000000-23-000404 to Renren Inc. (MTBLY) (CIK 0001509223) (MTBLY)
Renren Inc. (MTBLY) (CIK 0001509223)
Date: Jan. 13, 2023 · CIK: 0001509223 · Accession: 0000000000-23-000404
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File numbers found in text: 001-35147
Letter
United States securities and exchange commission logo January 13, 2023 Joseph Chen Chairman of the Board of Directors and Chief Executive Officer Renren Inc. 2828 N. Central Avenue, Fl 7 Phoenix, AZ 85004 Re:Renren Inc. Form 20-F for the Fiscal Year Ended December 31, 2021 Response Dated January 3, 2023 File No. 001-35147 Dear Joseph Chen: We have reviewed your January 3, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 1, 2022 letter. Form 20-F for the Fiscal Year Ended December 31, 2021 Notes to the Consolidated Financial Statements 15. Segment Information and Geographic Information, page F-51 1.Please address the following to help us further analyze your response to comment 4: •We note that Chime’s platform was launched under your ownership in 2016, while Trucker Path’s was purchased in 2017. Tell us how you considered the fact that the technologies underlying the SaaS are presumably different for Chime and Trucker Path in determining that the SaaS provided by Chime and Trucker are same or similar. •Provide an analysis to support your assertion that the economic characteristics of Chime and Trucker Path are similar. In this regard, you may provide revenues and gross profit and their respective trends for Chime and Trucker Path.
FirstName LastNameJoseph Chen Comapany NameRenren Inc. January 13, 2023 Page 2 FirstName LastName Joseph Chen Renren Inc. January 13, 2023 Page 2 2.We note your response to comment 5. However, we note that your websites show that Chime offers Responsive CRM, Intelligent IDX, and Optimized Marketing and Trucker Path offers Trucker Path app, Trucker Path Dispatch, Trucker Path Command, and TruckLoads. Please disclose the disaggregated revenues for the various products you offer. You may contact Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
January 13, 2023
Joseph Chen
Chairman of the Board of Directors and Chief Executive Officer
Renren Inc.
2828 N. Central Avenue, Fl 7
Phoenix, AZ 85004
Re:Renren Inc.
Form 20-F for the Fiscal Year Ended December 31, 2021
Response Dated January 3, 2023
File No. 001-35147
Dear Joseph Chen:
We have reviewed your January 3, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 1, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Notes to the Consolidated Financial Statements
15. Segment Information and Geographic Information, page F-51
1.Please address the following to help us further analyze your response to comment 4:
•We note that Chime’s platform was launched under your ownership in 2016, while
Trucker Path’s was purchased in 2017. Tell us how you considered the fact that the
technologies underlying the SaaS are presumably different for Chime and Trucker
Path in determining that the SaaS provided by Chime and Trucker are same or
similar.
•Provide an analysis to support your assertion that the economic characteristics of
Chime and Trucker Path are similar. In this regard, you may provide revenues and
gross profit and their respective trends for Chime and Trucker Path.
FirstName LastNameJoseph Chen
Comapany NameRenren Inc.
January 13, 2023 Page 2
FirstName LastName
Joseph Chen
Renren Inc.
January 13, 2023
Page 2
2.We note your response to comment 5. However, we note that your websites show that
Chime offers Responsive CRM, Intelligent IDX, and Optimized Marketing and Trucker
Path offers Trucker Path app, Trucker Path Dispatch, Trucker Path Command, and
TruckLoads. Please disclose the disaggregated revenues for the various products you
offer.
You may contact Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services