SEC Comment Letter 0000000000-23-000467 to UPWORK, INC (UPWK) (CIK 0001627475) (UPWK)
UPWORK, INC (UPWK) (CIK 0001627475)
Date: Jan. 17, 2023 · CIK: 0001627475 · Accession: 0000000000-23-000467
AI Filing Summary & Sentiment
File numbers found in text: 001-38678
Letter
United States securities and exchange commission logo January 17, 2023 Hayden Brown President and Chief Executive Officer Upwork Inc. 475 Brannan Street, Suite 430 San Francisco, California 94107 Re:Upwork Inc. Form 10-K for the Year Ended December 31, 2021 Filed February 15, 2022 File No. 001-38678 Dear Hayden Brown: We have reviewed your December 23, 2022 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 November 22, 2022 letter. Form 10-K for the Year Ended December 31, 2021 General 1.We note your response to prior comment 2. Please provide us, on an unconsolidated basis, the percentage of Upwork Inc’s assets that constitute “investment securities” as such term is used in Section 3(a)(1)(C) of the Investment Company Act of 1940 (the “1940 Act”). When performing this calculation, only include those assets that are recognized by U.S. generally accepted accounting principles.
FirstName LastNameHayden Brown Comapany NameUpwork Inc. January 17, 2023 Page 2 FirstName LastName Hayden Brown Upwork Inc. January 17, 2023 Page 2 You may contact Chen Chen, Staff Accountant, at (202) 551-7351 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Brian Levey
Show Raw Text
United States securities and exchange commission logo
January 17, 2023
Hayden Brown
President and Chief Executive Officer
Upwork Inc.
475 Brannan Street, Suite 430
San Francisco, California 94107
Re:Upwork Inc.
Form 10-K for the Year Ended December 31, 2021
Filed February 15, 2022
File No. 001-38678
Dear Hayden Brown:
We have reviewed your December 23, 2022 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
November 22, 2022 letter.
Form 10-K for the Year Ended December 31, 2021
General
1.We note your response to prior comment 2. Please provide us, on an unconsolidated
basis, the percentage of Upwork Inc’s assets that constitute “investment securities” as
such term is used in Section 3(a)(1)(C) of the Investment Company Act of 1940 (the
“1940 Act”). When performing this calculation, only include those assets that are
recognized by U.S. generally accepted accounting principles.
FirstName LastNameHayden Brown
Comapany NameUpwork Inc.
January 17, 2023 Page 2
FirstName LastName
Hayden Brown
Upwork Inc.
January 17, 2023
Page 2
You may contact Chen Chen, Staff Accountant, at (202) 551-7351 or Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Brian Levey