SEC Comment Letter for GoDaddy Inc. (GDDY) (CIK 0001609711) (GDDY) — Aug 13, 2019
GoDaddy Inc. (GDDY) (CIK 0001609711)
Date: Aug. 13, 2019 · CIK: 0001609711 · Accession: 0000000000-19-012437
AI Filing Summary & Sentiment
File numbers found in text: 001-36904
Letter
August 13, 2019 Ray Winborne Chief Financial Officer GoDaddy Inc. 14455 N. Hayden Road Scottsdale, Arizona 85260 Re:GoDaddy Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 22, 2019 Form 10-Q for the Quarterly Period Ended June 30, 2019 Filed August 2, 2019 File No. 001-36904 Dear Mr. Winborne: We have reviewed your filing 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 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 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. Form 10-Q for the Quarterly Period Ended June 30, 2019 Note 11. Commitments and Contingencies Litigation, page 19 1.We note your disclosures regarding the agreement in principle to settle the class action complaint. Please describe for us the terms, obligations and rights associated with the proposed settlement and describe your proposed accounting for each of the elements of the settlement. As part of your response, explain your basis for only accruing $18 million of the $35 million settlement. Also, explain why the amounts related to class members who elect to receive credits for future purchases will be classified as an offset to revenue and why these amounts will be recorded in the future as purchases are made. We refer you to ASC 450-20-25-2.
FirstName LastNameRay Winborne Comapany NameGoDaddy Inc. August 13, 2019 Page 2 FirstName LastName Ray Winborne GoDaddy Inc. August 13, 2019 Page 2 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 Eiko Yaoita Pyles, Staff Accountant at 202-551-3587 or Christine Dietz, Assistant Chief Accountant, at 202-551-3408 if you have any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services
Show Raw Text
August 13, 2019
Ray Winborne
Chief Financial Officer
GoDaddy Inc.
14455 N. Hayden Road
Scottsdale, Arizona 85260
Re:GoDaddy Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 22, 2019
Form 10-Q for the Quarterly Period Ended June 30, 2019
Filed August 2, 2019
File No. 001-36904
Dear Mr. Winborne:
We have reviewed your filing 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 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
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.
Form 10-Q for the Quarterly Period Ended June 30, 2019
Note 11. Commitments and Contingencies
Litigation, page 19
1.We note your disclosures regarding the agreement in principle to settle the class action
complaint. Please describe for us the terms, obligations and rights associated with the
proposed settlement and describe your proposed accounting for each of the elements of
the settlement. As part of your response, explain your basis for only accruing $18 million
of the $35 million settlement. Also, explain why the amounts related to class members
who elect to receive credits for future purchases will be classified as an offset to revenue
and why these amounts will be recorded in the future as purchases are made. We refer
you to ASC 450-20-25-2.
FirstName LastNameRay Winborne
Comapany NameGoDaddy Inc.
August 13, 2019 Page 2
FirstName LastName
Ray Winborne
GoDaddy Inc.
August 13, 2019
Page 2
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 Eiko Yaoita Pyles, Staff Accountant at 202-551-3587 or Christine
Dietz, Assistant Chief Accountant, at 202-551-3408 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services