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SEC Comment Letter 0000000000-22-012495 to Freshworks Inc. (FRSH) (CIK 0001544522) (FRSH)

Freshworks Inc. (FRSH) (CIK 0001544522)
Date: Nov. 17, 2022 · CIK: 0001544522 · Accession: 0000000000-22-012495

AI Filing Summary & Sentiment

File numbers found in text: 001-40806

Date
November 17, 2022
Author
Office of Technology
Form
UPLOAD
Company
Freshworks Inc. (FRSH) (CIK 0001544522)

Letter

United States securities and exchange commission logo November 17, 2022 Rathna Girish Mathrubootham Chief Executive Officer Freshworks Inc. 2950 S. Delaware Street, Suite 201 San Mateo, CA 94403 Re:Freshworks Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 23, 2022 File No. 001-40806 Dear Rathna Girish Mathrubootham: 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, 2021 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Key Business Metrics, page 50 1.We note that you continue to provide the number of customers contributing more then $5,000 in ARR as a key business metric. Please revise to disclose the percentage of ARR attributable to these customers for each period presented to provide context to such measure. We refer you to comment 12 in your June 25, 2021 response letter. Also, tell us your consideration to include the number of such customers and the percentage growth in ARR related to such customers for each period for which a statement of operations is presented. 2.Please tell us whether you continue to include monthly subscriptions in your calculation of net dollar retention rate. If so, revise to include a discussion of how monthly subscriptions factor into such calculations and how ARR and net dollar retention rates may be impacted

FirstName LastNameRathna Girish Mathrubootham Comapany NameFreshworks Inc. November 17, 2022 Page 2 FirstName LastName Rathna Girish Mathrubootham Freshworks Inc. November 17, 2022 Page 2 if such contracts are not renewed. Lastly, disclose the percentage of ARR from monthly subscriptions for each period presented. We refer to you to comment 7 in your July 19, 2021 response letter. Results of Operations, page 54 3.You attribute the increase in revenue for fiscal 2021 compared to 2020 to increases in additional agents enabled by your customers, sales to existing customers and the addition of new customers. Where a material changes from period-to-period is due to two or more factors, including any offsetting factors, revise to describe the underlying reasons for these material changes in both quantitative and qualitative terms. Refer to Item 303(b) of Regulation S-K. Item 8. Financial Statements and Supplementary Data Note 14. Geographic Information, page 96 4.We note that you generate a significant amount of revenue from international operations. Please tell us whether North America is comprised of only the United States. If not, revise to disclose revenue from your country of domicile separately from all other countries. Also, tell us whether revenue from any individual country is material and if so, how you considered the guidance in ASC 280-10-50-41(a) to disclose such revenue. 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 Megan Akst, Senior Staff Accountant at 202-551-3407 or Kathleen Collins, Accounting Brach Chief at 202-551-3499 if you have questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jon Avina

Show Raw Text
United States securities and exchange commission logo
November 17, 2022
Rathna Girish Mathrubootham
Chief Executive Officer
Freshworks Inc.
2950 S. Delaware Street, Suite 201
San Mateo, CA 94403
Re:Freshworks Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 23, 2022
File No. 001-40806
Dear Rathna Girish Mathrubootham:
            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, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Business Metrics, page 50
1.We note that you continue to provide the number of customers contributing more then
$5,000 in ARR as a key business metric. Please revise to disclose the percentage of ARR
attributable to these customers for each period presented to provide context to such
measure. We refer you to comment 12 in your June 25, 2021 response letter.  Also, tell us
your consideration to include the number of such customers and the percentage growth in
ARR related to such customers for each period for which a statement of operations is
presented.
2.Please tell us whether you continue to include monthly subscriptions in your calculation of
net dollar retention rate.  If so, revise to include a discussion of how monthly subscriptions
factor into such calculations and how ARR and net dollar retention rates may be impacted

 FirstName LastNameRathna Girish  Mathrubootham
 Comapany NameFreshworks Inc.
 November 17, 2022 Page 2
 FirstName LastName
Rathna Girish  Mathrubootham
Freshworks Inc.
November 17, 2022
Page 2
if such contracts are not renewed.  Lastly, disclose the percentage of ARR from monthly
subscriptions for each period presented.  We refer to you to comment 7 in your July 19,
2021 response letter.
Results of Operations, page 54
3.You attribute the increase in revenue for fiscal 2021 compared to 2020 to increases in
additional agents enabled by your customers, sales to existing customers and the addition
of new customers.  Where a material changes from period-to-period is due to two or more
factors, including any offsetting factors, revise to describe the underlying reasons for these
material changes in both quantitative and qualitative terms.  Refer to Item 303(b) of
Regulation S-K.
Item 8. Financial Statements and Supplementary Data
Note 14. Geographic Information, page 96
4.We note that you generate a significant amount of revenue from international operations.
Please tell us whether North America is comprised of only the United States.  If not,
revise to disclose revenue from your country of domicile separately from all other
countries.  Also, tell us whether revenue from any individual country is material and if so,
how you considered the guidance in ASC 280-10-50-41(a) to disclose such revenue.
            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 Megan Akst, Senior Staff Accountant at 202-551-3407 or Kathleen
Collins, Accounting Brach Chief at 202-551-3499 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Jon Avina