SEC Comment Letter for GoDaddy Inc. (GDDY) (CIK 0001609711) (GDDY) — Jun 14, 2018
GoDaddy Inc. (GDDY) (CIK 0001609711)
Date: June 14, 2018 · CIK: 0001609711 · Accession: 0000000000-18-018426
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36904
Letter
June 14, 2018 Ray E. Winborne Chief Financial Officer GoDaddy Inc. 14455 N. Hayden Rd Scottsdale, AZ 85260 Re:GoDaddy Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 27, 2018 Form 10-Q for the Quarterly Period Ended March 31, 2018 Filed May 9, 2018 File No. 001-36904 Dear Mr. Winborne: We have limited our review of your filing to the financial statements and related disclosures 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-Q for the Quarterly Period Ended March 31, 2018 Note 2. Summary of Significant Accounting Policies Revenue Recognition, page 8 1.Please help us better understand the nature of the goods and services transferred to your customers in your domain name registration business. Tell us which services you have combined with others for the purposes of determining your performance obligations and which services you have treated as a separate performance obligation. Refer to ASC 606- 10-25-21 and ASC 606-10-50-12 (c).
FirstName LastNameRay E. Winborne Comapany NameGoDaddy Inc. June 14, 2018 Page 2 FirstName LastName Ray E. Winborne GoDaddy Inc. June 14, 2018 Page 2 2.You disclose that revenue is recognized over the period which the performance obligations are satisfied. For domain name registration, please provide us with your analysis as to how you determined that domain name registration revenue should be recognized over time. Refer to ASC 606-10-25-27. 3.Regarding the assets recognized from the costs to obtain a contract, please disclose the amount of related amortization expense recognized during the period. Refer to ASC 340- 40-50-3(b). 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 Joyce Sweeney, Senior Staff Accountant at 202-551-3449 or Christine Dietz, Assistant Chief Accountant at 202-551-3408 with any questions. Division of Corporation Finance Office of Information Technologies and Services cc: Rezwan D. Pavri, Wilson Sonsini Goodrich & Rosati, P.C.
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June 14, 2018
Ray E. Winborne
Chief Financial Officer
GoDaddy Inc.
14455 N. Hayden Rd
Scottsdale, AZ 85260
Re:GoDaddy Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed February 27, 2018
Form 10-Q for the Quarterly Period Ended March 31, 2018
Filed May 9, 2018
File No. 001-36904
Dear Mr. Winborne:
We have limited our review of your filing to the financial statements and related
disclosures 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-Q for the Quarterly Period Ended March 31, 2018
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page 8
1.Please help us better understand the nature of the goods and services transferred to your
customers in your domain name registration business. Tell us which services you have
combined with others for the purposes of determining your performance obligations and
which services you have treated as a separate performance obligation. Refer to ASC 606-
10-25-21 and ASC 606-10-50-12 (c).
FirstName LastNameRay E. Winborne
Comapany NameGoDaddy Inc.
June 14, 2018 Page 2
FirstName LastName
Ray E. Winborne
GoDaddy Inc.
June 14, 2018
Page 2
2.You disclose that revenue is recognized over the period which the performance
obligations are satisfied. For domain name registration, please provide us with your
analysis as to how you determined that domain name registration revenue should be
recognized over time. Refer to ASC 606-10-25-27.
3.Regarding the assets recognized from the costs to obtain a contract, please disclose the
amount of related amortization expense recognized during the period. Refer to ASC 340-
40-50-3(b).
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 Joyce Sweeney, Senior Staff Accountant at 202-551-3449 or Christine
Dietz, Assistant Chief Accountant at 202-551-3408 with any questions.
Division of Corporation Finance
Office of Information Technologies
and Services
cc: Rezwan D. Pavri, Wilson Sonsini Goodrich & Rosati, P.C.