SEC Comment Letter 0000000000-23-004260 to Udemy, Inc. (UDMY) (CIK 0001607939) (UDMY)
Udemy, Inc. (UDMY) (CIK 0001607939)
Date: April 26, 2023 · CIK: 0001607939 · Accession: 0000000000-23-004260
AI Filing Summary & Sentiment
File numbers found in text: 001-40956
Letter
United States securities and exchange commission logo April 26, 2023 Sarah Blanchard Chief Financial Officer Udemy, Inc. 600 Harrison Street , 3rd Floor San Francisco, CA 94107 Re:Udemy, Inc. Form 10-K for the Year Ended December 31, 2022 Filed February 27, 2023 Earnings Release on Form 8-K Furnished February 14, 2023 File No. 001-40956 Dear Sarah Blanchard: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the 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 the comment, we may have additional comments. Earnings Release on Form 8-K Furnished February 14, 2023 Exhibit 99.1 Udemy Reports Fourth Quarter and Full Year 2022 Results Reconciliation of GAAP to Non-GAAP Financial Measures, page 8 1.Your non-GAAP reconciliations for the interim and annual periods appear to present non- GAAP income statements. This presentation appears to be inconsistent with Question 102.10(c) of the staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please advise, or revise to remove the current presentation and reconcile each non-GAAP measure separately.
FirstName LastNameSarah Blanchard Comapany NameUdemy, Inc. April 26, 2023 Page 2 FirstName LastName Sarah Blanchard Udemy, Inc. April 26, 2023 Page 2 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 Robert Shapiro at 202-551-3273 or Abe Friedman at 202-551-8298 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
April 26, 2023
Sarah Blanchard
Chief Financial Officer
Udemy, Inc.
600 Harrison Street , 3rd Floor
San Francisco, CA 94107
Re:Udemy, Inc.
Form 10-K for the Year Ended December 31, 2022
Filed February 27, 2023
Earnings Release on Form 8-K
Furnished February 14, 2023
File No. 001-40956
Dear Sarah Blanchard:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to the 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 the comment, we may have additional comments.
Earnings Release on Form 8-K Furnished February 14, 2023
Exhibit 99.1
Udemy Reports Fourth Quarter and Full Year 2022 Results
Reconciliation of GAAP to Non-GAAP Financial Measures, page 8
1.Your non-GAAP reconciliations for the interim and annual periods appear to present non-
GAAP income statements. This presentation appears to be inconsistent with Question
102.10(c) of the staff's Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures. Please advise, or revise to remove the current
presentation and reconcile each non-GAAP measure separately.
FirstName LastNameSarah Blanchard
Comapany NameUdemy, Inc.
April 26, 2023 Page 2
FirstName LastName
Sarah Blanchard
Udemy, Inc.
April 26, 2023
Page 2
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 Robert Shapiro at 202-551-3273 or Abe Friedman at 202-551-8298
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services