SEC Comment Letter for Criteo S.A. (CRTO) (CIK 0001576427) (CRTO) — Oct 20, 2016
Criteo S.A. (CRTO) (CIK 0001576427)
Date: Oct. 20, 2016 · CIK: 0001576427 · Accession: 0000000000-16-097835
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 7, 2016
Letter
Mail Stop 3720 October 20 , 2016 Eric Eichmann Chief Executive Officer Criteo S.A. 32 rue Blanche Paris, France 75009
Re: Criteo S.A. Form 10 -K for Fiscal Year Ended December 31, 2015 Filed February 29, 2016 File No. 001 -36153
Dear Mr. Eichmann:
We have reviewed your filing and have the following comment . Please comply with th is comment in future filings. Confirm in wr iting that you will do so. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to th is comment 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 comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our letter dated September 7, 2016.
Form 10 -K for Fiscal Year Ended December 31, 2015
Note 17. Nature of Expenses Allocated to Cost of Revenue, page F -38
1. We note your response to prior comment four. Specifically, you stated that none of your R&D employees are “solely” dedicated to revenue -generating activities and that the Technical Solutions Business Intelligence and Creative Services teams are “not directly related” to revenue generating activities. Please confirm to us that ti me spent (if any) by your R&D employees and Technical Solutions Business Intelligence and Creative Services teams that are attributable to revenue -generating activities, including customization of the Criteo Engine capabilities for certain clients, are not material.
Eric Eichmann Criteo S.A. October 20 , 2016 Page 2
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 Kathryn Jacobson, Senior St aff Accountant, at (202) 551 -3365 or Dean Suehiro, Senior Staff Accountant, at (202) 551 -3384 if you have questions regarding our comment on the financial statements and related matters. Please contact Lahdan Rahmati, Law Clerk, at (202) 551 -8199, or Kath leen Krebs, Special Counsel, at (202) 551 -3350, or me at (202) 551-3810 with any other questions.
Sincerely,
/s/ Celeste M. Mur phy for
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Mail Stop 3720 October 20 , 2016 Eric Eichmann Chief Executive Officer Criteo S.A. 32 rue Blanche Paris, France 75009 Re: Criteo S.A. Form 10 -K for Fiscal Year Ended December 31, 2015 Filed February 29, 2016 File No. 001 -36153 Dear Mr. Eichmann: We have reviewed your filing and have the following comment . Please comply with th is comment in future filings. Confirm in wr iting that you will do so. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to th is comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our letter dated September 7, 2016. Form 10 -K for Fiscal Year Ended December 31, 2015 Note 17. Nature of Expenses Allocated to Cost of Revenue, page F -38 1. We note your response to prior comment four. Specifically, you stated that none of your R&D employees are “solely” dedicated to revenue -generating activities and that the Technical Solutions Business Intelligence and Creative Services teams are “not directly related” to revenue generating activities. Please confirm to us that ti me spent (if any) by your R&D employees and Technical Solutions Business Intelligence and Creative Services teams that are attributable to revenue -generating activities, including customization of the Criteo Engine capabilities for certain clients, are not material. Eric Eichmann Criteo S.A. October 20 , 2016 Page 2 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 Kathryn Jacobson, Senior St aff Accountant, at (202) 551 -3365 or Dean Suehiro, Senior Staff Accountant, at (202) 551 -3384 if you have questions regarding our comment on the financial statements and related matters. Please contact Lahdan Rahmati, Law Clerk, at (202) 551 -8199, or Kath leen Krebs, Special Counsel, at (202) 551 -3350, or me at (202) 551-3810 with any other questions. Sincerely, /s/ Celeste M. Mur phy for Larry Spirgel Assistant Director