SEC Comment Letter for GoDaddy Inc. (GDDY) (CIK 0001609711) (GDDY) — Jul 13, 2018
GoDaddy Inc. (GDDY) (CIK 0001609711)
Date: July 13, 2018 · CIK: 0001609711 · Accession: 0000000000-18-021532
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36904
Letter
July 13, 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 reviewed your June 22, 2018 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 June 14, 2018 letter. Form 10-Q for the Quarterly Period Ended March 31, 2018 Note 2. Summary of Significant Accounting Policies Revenue Recognition, page 8 1.We note your response to prior comment 1. Please revise to describe the nature of the services provided for your domain registry services performance obligation and the judgments and assumptions made in concluding that this represents a single performance obligation. Refer to ASC 606-10-50-12.
FirstName LastNameRay E. Winborne Comapany NameGoDaddy Inc. July 13, 2018 Page 2 FirstName LastName Ray E. Winborne GoDaddy Inc. July 13, 2018 Page 2 2.We note your response to prior comment 3. Please tell us the amount of amortization expense related to prepaid domain registry fees for the quarter ended March 31, 2018 and whether you believe such fees are contract fulfillment costs. If so, disclose the amount of amortization expense recognized during the period. Refer to ASC 340-40-25-5 and ASC 340-40-50-3(b). 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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July 13, 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 reviewed your June 22, 2018 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
June 14, 2018 letter.
Form 10-Q for the Quarterly Period Ended March 31, 2018
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page 8
1.We note your response to prior comment 1. Please revise to describe the nature of the
services provided for your domain registry services performance obligation and the
judgments and assumptions made in concluding that this represents a single performance
obligation. Refer to ASC 606-10-50-12.
FirstName LastNameRay E. Winborne
Comapany NameGoDaddy Inc.
July 13, 2018 Page 2
FirstName LastName
Ray E. Winborne
GoDaddy Inc.
July 13, 2018
Page 2
2.We note your response to prior comment 3. Please tell us the amount of amortization
expense related to prepaid domain registry fees for the quarter ended March 31, 2018 and
whether you believe such fees are contract fulfillment costs. If so, disclose the amount of
amortization expense recognized during the period. Refer to ASC 340-40-25-5 and ASC
340-40-50-3(b).
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.