SEC Comment Letter 0000000000-22-013443 to Zoom Communications, Inc. (ZM) (CIK 0001585521) (ZM)
Zoom Communications, Inc. (ZM) (CIK 0001585521)
Date: Dec. 14, 2022 · CIK: 0001585521 · Accession: 0000000000-22-013443
AI Filing Summary & Sentiment
File numbers found in text: 001-38865
Letter
United States securities and exchange commission logo December 14, 2022 Kelly Steckelberg Chief Financial Officer Zoom Video Communications, Inc. 55 Almaden Boulevard 6th Floor San Jose, CA 95113 Re:Zoom Video Communications, Inc. Form 10-K for the Fiscal Year Ended January 31, 2022 Filed March 7, 2022 Form 10-Q for the Quarterly Period Ended October 31, 2022 Filed November 23, 2022 File No. 001-38865 Dear Kelly Steckelberg: We have reviewed your December 2, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our October 31, 2022 letter. Form 10 for the Quarterly Period Ended October 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Key Business Metrics, page 28 1.We note from your response to prior comment 2 that Entry MRR includes revenue from monthly subscribers that have not provided any indication that they intend to cancel their subscriptions. Please tell us how subscribers who have indicated that they intend to cancel their subscriptions are reflected in your MRR attrition rate calculations. In this regard, clarify whether such customers are included in the attrition rate of the prior quarter. If not, explain how attrition for such customers is captured in your customer
FirstName LastNameKelly Steckelberg Comapany NameZoom Video Communications, Inc. December 14, 2022 Page 2 FirstName LastName Kelly Steckelberg Zoom Video Communications, Inc. December 14, 2022 Page 2 churn calculations. Also, revise your disclosures as necessary to clarify how such customers are factored into your calculations. You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen Collins, Accounting Branch Chief, Accounting Branch Chief, at (202) 551-3499 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jon Avina
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United States securities and exchange commission logo
December 14, 2022
Kelly Steckelberg
Chief Financial Officer
Zoom Video Communications, Inc.
55 Almaden Boulevard
6th Floor
San Jose, CA 95113
Re:Zoom Video Communications, Inc.
Form 10-K for the Fiscal Year Ended January 31, 2022
Filed March 7, 2022
Form 10-Q for the Quarterly Period Ended October 31, 2022
Filed November 23, 2022
File No. 001-38865
Dear Kelly Steckelberg:
We have reviewed your December 2, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
October 31, 2022 letter.
Form 10 for the Quarterly Period Ended October 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Business Metrics, page 28
1.We note from your response to prior comment 2 that Entry MRR includes revenue from
monthly subscribers that have not provided any indication that they intend to cancel their
subscriptions. Please tell us how subscribers who have indicated that they intend to
cancel their subscriptions are reflected in your MRR attrition rate calculations. In this
regard, clarify whether such customers are included in the attrition rate of the prior
quarter. If not, explain how attrition for such customers is captured in your customer
FirstName LastNameKelly Steckelberg
Comapany NameZoom Video Communications, Inc.
December 14, 2022 Page 2
FirstName LastName
Kelly Steckelberg
Zoom Video Communications, Inc.
December 14, 2022
Page 2
churn calculations. Also, revise your disclosures as necessary to clarify how such
customers are factored into your calculations.
You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen
Collins, Accounting Branch Chief, Accounting Branch Chief, at (202) 551-3499 if you have
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Jon Avina