SEC Comment Letter for Uber Technologies, (UBER) — Apr 12, 2019
Uber Technologies, Inc
Date: April 12, 2019 · CIK: 0001543151 · Accession: 0000000000-19-007076
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April 12, 2019
Dara Khosrowshahi
Chief Executive Officer
Uber Technologies, Inc.
1455 Market Street, 4th Floor
San Francisco, CA 94103
Re:Uber Technologies, Inc.
Amendment No. 4 to
Draft Registration Statement on Form S-1
Submitted April 4, 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.
Amendment No. 4 to Draft Registration Statement
General
1.We note that you entered into an asset purchase agreement to acquire Careem Inc. and its
subsidiaries in March 2019 for a purchase price of approximately $3.1 billion. Provide us
with your analysis of the significance of the acquired company pursuant to Rule 3-05 of
Regulation S-X. If it is greater than 50% significant, please provide us with your analysis
as to whether you deem the acquisition to be probable.
Exhibit Index, page II-8
2.Please file the asset purchase agreement with Careem as an exhibit or explain to us why
FirstName LastNameDara Khosrowshahi
Comapany NameUber Technologies, Inc.
April 12, 2019 Page 2
FirstName LastName
Dara Khosrowshahi
Uber Technologies, Inc.
April 12, 2019
Page 2
this is not required by Item 601(b)(2) or (b)(10) to Regulation S-K.
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.