SEC Comment Letter for Sumo Logic, Inc. (CIK 0001643269) — Apr 21, 2020
Sumo Logic, Inc. (CIK 0001643269)
Date: April 21, 2020 · CIK: 0001643269 · Accession: 0000000000-20-003419
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April 21, 2020
Ramin Sayar
Chief Executive Officer
Sumo Logic, Inc.
305 Main Street
Redwood City, CA 94063
Re:Sumo Logic, Inc.
Amendment No. 3 to Draft Registration Statement on Form S-1
Submitted April 8, 2020
CIK: 0001643269
Dear Mr. Sayar:
We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1
Customer Case Studies, page 109
1.You present case studies of customers that have utilized your services. Please confirm that
the customers have consented to these statements and to their case studies being used in
your registration statement and explain the criteria you used in selecting the profiled
clients and how these clients provide a meaningful representation of your user base. Also,
disclose the time periods covered by the case studies, as well as any limitations in using
these individual case studies.
FirstName LastNameRamin Sayar
Comapany NameSumo Logic, Inc.
April 21, 2020 Page 2
FirstName LastName
Ramin Sayar
Sumo Logic, Inc.
April 21, 2020
Page 2
General
2.We refer to the graphic on the inside back cover page. Please balance the disclosure in the
graphic on the back cover page by including your net loss through January 31, 2020. In
addition, please clarify whether the Revenue Run Rate is calculated using monthly or
quarterly results and discuss the material underlying assumptions and limitations of the
figures presented.
You may contact Melissa Walsh, Staff Accountant, at (202) 551-3224 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Matthew Derby, Staff
Attorney, at (202) 551-3334 or Matthew Crispino, Staff Attorney, at (202) 551-3456 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Rezwan Pavri, Esq.