SEC Comment Letter 0000000000-24-000413 to Ibotta, Inc. (IBTA) (CIK 0001538379) (IBTA)
Ibotta, Inc. (IBTA) (CIK 0001538379)
Date: Jan. 11, 2024 · CIK: 0001538379 · Accession: 0000000000-24-000413
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo January 11, 2024 Bryan Leach Chief Executive Officer Ibotta, Inc. 1801 California Street Suite 400 Denver, CO 80202 Re:Ibotta, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted December 11, 2023 CIK No. 0001538379 Dear Bryan Leach: We have reviewed your amended draft registration statement and have the following comment(s). Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No.1 to Draft Registration Statement, Submitted December 11, 2023 Note 11: Redeemable Convertible Preferred Stock, Common Stock, Restricted Stock Purchase and Common Stock Warrants Common Stock Warrants, page F-26 1.We note your response to prior comment 5. Please tell us how you determined whether Walmart is considered your customer in these arrangements. Refer to ASC 606-10-32-25.
FirstName LastNameBryan Leach Comapany NameIbotta, Inc. January 11, 2024 Page 2 FirstName LastName Bryan Leach Ibotta, Inc. January 11, 2024 Page 2 Please contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if you have questions regarding comments on the financial statements and related matters. Please contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Rachel J. Nagashima
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United States securities and exchange commission logo
January 11, 2024
Bryan Leach
Chief Executive Officer
Ibotta, Inc.
1801 California Street
Suite 400
Denver, CO 80202
Re:Ibotta, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted December 11, 2023
CIK No. 0001538379
Dear Bryan Leach:
We have reviewed your amended draft registration statement and have the following
comment(s).
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No.1 to Draft Registration Statement, Submitted December 11, 2023
Note 11: Redeemable Convertible Preferred Stock, Common Stock, Restricted Stock Purchase
and Common Stock Warrants
Common Stock Warrants, page F-26
1.We note your response to prior comment 5. Please tell us how you determined whether
Walmart is considered your customer in these arrangements. Refer to ASC 606-10-32-25.
FirstName LastNameBryan Leach
Comapany NameIbotta, Inc.
January 11, 2024 Page 2
FirstName LastName
Bryan Leach
Ibotta, Inc.
January 11, 2024
Page 2
Please contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if you
have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Rachel J. Nagashima