SEC Comment Letter for Uber Technologies, (UBER) — Mar 19, 2019
Uber Technologies, Inc
Date: March 19, 2019 · CIK: 0001543151 · Accession: 0000000000-19-005204
AI Filing Summary & Sentiment
Referenced dates: February 1, 2019
Letter
March 19, 2019 Dara Khosrowshahi Chief Executive Officer Uber Technologies, Inc. 1455 Market Street, 4th Floor San Francisco, CA 94103 Re:Uber Technologies, Inc. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted March 12, 2019 CIK No. 0001543151 Dear Mr. Khosrowshahi: We have reviewed your amended draft registration statement 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 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 our comments apply 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 these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Draft Registration Statement Submitted March 12, 2019 Key Metrics and Non-GAAP Financial Measures, page 91 1.We are continuing to evaluate your response to comment 8 and may have additional comments. Notes to Consolidated Financial Statements Note 14 - Segment Information, page F-52 2.We are continuing to evaluate your responses to comments 34 and 35 in our letter dated February 1, 2019 and the CODM financial reporting package information we requested during our call on March 5, 2019. We may have additional comments.
FirstName LastNameDara Khosrowshahi Comapany NameUber Technologies, Inc. March 19, 2019 Page 2 FirstName LastName Dara Khosrowshahi Uber Technologies, Inc. March 19, 2019 Page 2 You may contact Melissa Gilmore, Staff Accountant, at (202) 551-3777 or Melissa Raminpour, Accounting Branch Chief, at (202) 551-3379 if you have questions regarding comments on the financial statements and related matters. Please contact J. Nolan McWilliams, Attorney-Advisor, at (202 551-3217 or Anne Nguyen Parker, Assistant Director, at (202) 551- 3611 with any other questions. Sincerely, Division of Corporation Finance Office of Transportation and Leisure cc: Dave Peinsipp, Esq.
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March 19, 2019
Dara Khosrowshahi
Chief Executive Officer
Uber Technologies, Inc.
1455 Market Street, 4th Floor
San Francisco, CA 94103
Re:Uber Technologies, Inc.
Amendment No. 2 to
Draft Registration Statement on Form S-1
Submitted March 12, 2019
CIK No. 0001543151
Dear Mr. Khosrowshahi:
We have reviewed your amended draft registration statement 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 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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement Submitted March 12, 2019
Key Metrics and Non-GAAP Financial Measures, page 91
1.We are continuing to evaluate your response to comment 8 and may have additional
comments.
Notes to Consolidated Financial Statements
Note 14 - Segment Information, page F-52
2.We are continuing to evaluate your responses to comments 34 and 35 in our letter dated
February 1, 2019 and the CODM financial reporting package information we requested
during our call on March 5, 2019. We may have additional comments.
FirstName LastNameDara Khosrowshahi
Comapany NameUber Technologies, Inc.
March 19, 2019 Page 2
FirstName LastName
Dara Khosrowshahi
Uber Technologies, Inc.
March 19, 2019
Page 2
You may contact Melissa Gilmore, Staff Accountant, at (202) 551-3777 or Melissa
Raminpour, Accounting Branch Chief, at (202) 551-3379 if you have questions regarding
comments on the financial statements and related matters. Please contact J. Nolan McWilliams,
Attorney-Advisor, at (202 551-3217 or Anne Nguyen Parker, Assistant Director, at (202) 551-
3611 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure
cc: Dave Peinsipp, Esq.