SEC Comment Letter for Uber Technologies, (UBER) — Mar 25, 2021
Uber Technologies, Inc
Date: March 25, 2021 · CIK: 0001543151 · Accession: 0000000000-21-003587
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United States securities and exchange commission logo March 25, 2021 Nelson Chai Chief Financial Officer Uber Technologies, Inc. 1515 3rd Street San Francisco, California 94158 Re:Uber Technologies, Inc. Form 10-K for the Fiscal Year Ended December 31, 2020 Filed March 1, 2021 File No. 1-38902 Dear Mr. Chai: We have limited our review of your filing to the financial statements and related disclosures 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, 2020 Notes to Consolidated Financial Statements Note 1 - Description of Business and Summary of Significant Accounting Policies Revenue Recognition, page 99 1.We note you have a membership or “Pass” program allowing users to unlock savings across platforms for a monthly fee. Please explain the significance of this program and your consideration of disclosing your accounting policy with regards to revenue recognition. Also, please explain how you allocate membership revenue across the segments offering this program. In closing, 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.
FirstName LastNameNelson Chai Comapany NameUber Technologies, Inc. March 25, 2021 Page 2 FirstName LastName Nelson Chai Uber Technologies, Inc. March 25, 2021 Page 2 You may contact Scott Stringer at 202-551-3272 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
March 25, 2021
Nelson Chai
Chief Financial Officer
Uber Technologies, Inc.
1515 3rd Street
San Francisco, California 94158
Re:Uber Technologies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed March 1, 2021
File No. 1-38902
Dear Mr. Chai:
We have limited our review of your filing to the financial statements and related
disclosures 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, 2020
Notes to Consolidated Financial Statements
Note 1 - Description of Business and Summary of Significant Accounting Policies
Revenue Recognition, page 99
1.We note you have a membership or “Pass” program allowing users to unlock savings
across platforms for a monthly fee. Please explain the significance of this program and
your consideration of disclosing your accounting policy with regards to revenue
recognition. Also, please explain how you allocate membership revenue across the
segments offering this program.
In closing, 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.
FirstName LastNameNelson Chai
Comapany NameUber Technologies, Inc.
March 25, 2021 Page 2
FirstName LastName
Nelson Chai
Uber Technologies, Inc.
March 25, 2021
Page 2
You may contact Scott Stringer at 202-551-3272 or Linda Cvrkel at 202-551-3813 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services