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SEC Comment Letter for Datadog, Inc. (DDOG) (CIK 0001561550) (DDOG) — May 4, 2020

Datadog, Inc. (DDOG) (CIK 0001561550)
Date: May 4, 2020 · CIK: 0001561550 · Accession: 0000000000-20-003858

AI Filing Summary & Sentiment

File numbers found in text: 001-39051

Date
May 1, 2020
Author
Office of Technology
Form
UPLOAD
Company
Datadog, Inc. (DDOG) (CIK 0001561550)

Letter

United States securities and exchange commission logo May 1, 2020 David Obstler Chief Financial Officer Datadog, Inc. 620 8th Avenue, 45th Floor New York, NY 10018 Re:Datadog, Inc. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 25, 2020 File No. 001-39051 Dear Mr. Obstler: 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 Management’s Discussion and Analysis of Financial Condition and Results of Operations Factors Affecting Our Performance, page 38 1.We note that your results of operations are impacted, in part, by your ability to retain and grow your existing customers. Please tell us what measures are used to evaluate the success of your land-and-expand business model and what consideration you have given to including a quantified discussion of such metrics for each period presented. In this regard, we note you previously provided a dollar-based net retention rate. Refer to Item 303(a)(3) of Regulation S-K and Section III.B.1 of SEC Release No. 33-8350. Refer also to SEC Release 33-10751.

FirstName LastNameDavid Obstler Comapany NameDatadog, Inc. May 1, 2020 Page 2 FirstName LastName David Obstler Datadog, Inc. May 1, 2020 Page 2 2.Please expand your disclosure to explain how management uses the measure of the number of customers with ARR greater than $100,000 to analyze the business and why disclosing this information is useful to investors. Also, to add further context to such measure, please disclose the percentage of ARR generated from this subset of customer for each period presented. Results of Operations, page 42 3.You state that revenue was primarily due to growth from existing customers with the remaining attributable to new customers. Where a material change is attributed to two or more factors, including any offsetting factors, please revise to quantify the contribution of each identified factor and remove any vague terms such as "primarily" in favor of specific quantification. Refer Section III.D of Release No. 33-6835. 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Kathleen Collins, Accounting Branch Chief, at 202-551-3499 with any questions. Sincerely, Division of Corporation Finance Office of Technology

Show Raw Text
United States securities and exchange commission logo
May 1, 2020
David Obstler
Chief Financial Officer
Datadog, Inc.
620 8th Avenue, 45th Floor
New York, NY 10018
Re:Datadog, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 25, 2020
File No. 001-39051
Dear Mr. Obstler:
            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
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Factors Affecting Our Performance, page 38
1.We note that your results of operations are impacted, in part, by your ability to retain and
grow your existing customers.  Please tell us what measures are used to evaluate the
success of your land-and-expand business model and what consideration you have given
to including a quantified discussion of such metrics for each period presented.  In this
regard, we note you previously provided a dollar-based net retention rate.  Refer to Item
303(a)(3) of Regulation S-K and Section III.B.1 of SEC Release No. 33-8350.  Refer also
to SEC Release 33-10751.

 FirstName LastNameDavid Obstler
 Comapany NameDatadog, Inc.
 May 1, 2020 Page 2
 FirstName LastName
David Obstler
Datadog, Inc.
May 1, 2020
Page 2
2.Please expand your disclosure to explain how management uses the measure of the
number of customers with ARR greater than $100,000 to analyze the business and why
disclosing this information is useful to investors. Also, to add further context to such
measure, please disclose the percentage of ARR generated from this subset of customer
for each period presented.
Results of Operations, page 42
3.You state that revenue was primarily due to growth from existing customers with the
remaining attributable to new customers. Where a material change is attributed to two or
more factors, including any offsetting factors, please revise to quantify the contribution of
each identified factor and remove any vague terms such as "primarily" in favor of specific
quantification.  Refer Section III.D of Release No. 33-6835.
            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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Kathleen
Collins, Accounting Branch Chief, at 202-551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology