SEC Comment Letter 0000000000-23-004685 to MAGNITE, INC. (MGNI) (CIK 0001595974) (MGNI)
MAGNITE, INC. (MGNI) (CIK 0001595974)
Date: May 5, 2023 · CIK: 0001595974 · Accession: 0000000000-23-004685
AI Filing Summary & Sentiment
File numbers found in text: 001-36384
Letter
United States securities and exchange commission logo May 5, 2023 David Day Chief Financial Officer Magnite, Inc. 1250 Broadway, 15th Floor, New York, New York 10001 Re:Magnite, Inc. Form 10-K filed on February 22, 2023 File No. 001-36384 Dear David Day: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K filed on February 22, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Key Operating and Financial Performance Metrics, page 50 1.Your non-GAAP performance measure labeled as "Revenue ex-TAC" suggest that the comparable GAAP measure is revenue, however, gross profit is the comparable GAAP measure. Please consider revising the name of your "Revenue ex-TAC" measure to reflect its nature as being more akin to gross profit. We refer you to Question 100.5 of the Compliance & Disclosure Interpretations on Non-GAAP Measures. 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. You may contact Becky Chow, Staff Accountant at 202-551-6524, or Stephen Krikorian,
FirstName LastNameDavid Day Comapany NameMagnite, Inc. May 5, 2023 Page 2 FirstName LastName David Day Magnite, Inc. May 5, 2023 Page 2 Accounting Branch Chief, at 202-551-3488 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
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United States securities and exchange commission logo
May 5, 2023
David Day
Chief Financial Officer
Magnite, Inc.
1250 Broadway,
15th Floor,
New York, New York 10001
Re:Magnite, Inc.
Form 10-K filed on February 22, 2023
File No. 001-36384
Dear David Day:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to this 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K filed on February 22, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Operating and Financial Performance Metrics, page 50
1.Your non-GAAP performance measure labeled as "Revenue ex-TAC" suggest that the
comparable GAAP measure is revenue, however, gross profit is the comparable GAAP
measure. Please consider revising the name of your "Revenue ex-TAC" measure to reflect
its nature as being more akin to gross profit. We refer you to Question 100.5 of the
Compliance & Disclosure Interpretations on Non-GAAP Measures.
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.
You may contact Becky Chow, Staff Accountant at 202-551-6524, or Stephen Krikorian,
FirstName LastNameDavid Day
Comapany NameMagnite, Inc.
May 5, 2023 Page 2
FirstName LastName
David Day
Magnite, Inc.
May 5, 2023
Page 2
Accounting Branch Chief, at 202-551-3488 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology