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United States securities and exchange commission logo
March 28, 2024
Mark McCaffrey
Chief Financial Officer
GoDaddy Inc.
2155 E. GoDaddy Way
Tempe, AZ 85284
Re:GoDaddy Inc.
Form 10-K for the fiscal year ended December 31, 2023
File No. 001-36904
Dear Mark McCaffrey:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Our Financial Model, page 66
1.We note your customer retention rate for each of the five years ended December 31,
2023 was approximately 85%, which appears to indicate that it has decreased since prior
periods when you disclosed it exceeded 85%. Similarly, the retention rate for customers
who have been with you over three years as of 2023 was approximately 92% compared to
disclosure in prior years that stated it was more than 93%. Please provide in your response
the customer retention rates for each period in the respective three- and five-year periods.
Also, tell us what consideration was given to disclosing the exact customer retention rate
for each period and including a discussion of significant fluctuations between periods.
Refer to SEC Release No. 33-10751.

 FirstName LastNameMark McCaffrey
 Comapany NameGoDaddy Inc.
 March 28, 2024 Page 2
 FirstName LastName
Mark McCaffrey
GoDaddy Inc.
March 28, 2024
Page 2
Results of Operations
Year-Over-Year Comparison, page 69
2.We note fluctuations between periods in cost of revenue and other expense line items and
Segment EBITDA are due to two or more factors, some of which are offsetting. We also
note your reference to changes being due "primarily" to these factors. Where a material
change is attributed to two or more factors, including any offsetting factors, revise to
describe the contribution of each factor in quantified terms. Please also revise to use more
definitive terminology, rather than general or vague terms such as "primarily," to describe
each contributing factor. Refer to Item 303(b) of Regulation S-K and Section III.D of SEC
Release No. 33-6835.
General
2023 Fourth Quarter Earnings Presentation
3.We note your presentation of free cash flow per share throughout the 2023 Fourth Quarter
Earnings Presentation on your website. Please revise to remove this presentation as non-
GAAP liquidity measures that measure cash generated must not be presented on a per
share basis. Refer to 100(b) of Regulation G.
4.We also note disclosure of Total Liquidity in your earnings presentation on your website.
Please revise to explain how Total Liquidity is determined. If Total Liquidity is a non-
GAAP measure, revise to provide the disclosures required by Item 100(a) of Regulation
G.
            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.
            Please contact Brittany Ebbertt at 202-551-3572 or Christine Dietz at 202-551-3408 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Alan Denenberg