SecProbe.io

April 3, 2020
Nelson Chai
Chief Financial Officer
Uber Technologies, Inc
1455 Market Street, 4th Floor
San Francisco, California 94103
Re:Uber Technologies, Inc
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 2, 2020
File No. 1-38902
Dear Mr. Chai:
            We have reviewed your filing 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.
Form 10-K for the fiscal year ended December 31, 2019
Legal Proceedings
Australia Class Action, page 44
1.Please tell us your consideration of disclosing the relief sought in the class action matter
filed in May 2019.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Certain Key Metrics and Non-GAAP Financial Measures, page 51
2.We note your discussion and presentation of non-GAAP financial measures precede your
discussion and presentation of your results of operations on a GAAP basis.  Please tell us
your consideration of Question 102.10 of our Compliance & Disclosure Interpretations on
Non-GAAP Financial Measures.

 FirstName LastNameNelson Chai
 Comapany NameUber Technologies, Inc
 April 3, 2020 Page 2
 FirstName LastName
Nelson Chai
Uber Technologies, Inc
April 3, 2020
Page 2
Results of Operations, page 55
3.Please revise your disclosures in future filings to quantify factors primarily responsible for
changes pursuant to Item 303 of Regulation S-K. When a change is attributable to more
than one factor, please quantify each material component.  For example, you state certain
increases such as sales and marketing expenses were “primarily” attributed to an increase
in consumer discounts, rider facing loyalty expense, promotions, credits and refunds,
stock-based compensation and employee headcount costs.  Refer to SEC Release No. 33-
8350.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Donna Di Silvio at (202) 551-3202 or Bill Thompson at (202) 551-3344
if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Keir Gumbs