SEC Comment Letter for BLACKLINE, INC. (BL) (CIK 0001666134) (BL) — Apr 23, 2020
BLACKLINE, INC. (BL) (CIK 0001666134)
Date: April 23, 2020 · CIK: 0001666134 · Accession: 0000000000-20-003485
AI Filing Summary & Sentiment
File numbers found in text: 001-37924
Letter
April 22, 2020 Mark Partin Chief Financial Officer Blackline, Inc. 21300 Victory Boulevard, 12th Floor Woodland Hills, CA 91367 Re:Blackline, Inc. Form 10-K for the Year Ended December 31, 2019 Filed February 27, 2020 File No. 001-37924 Dear Mr. Partin: We have reviewed your filing and have the following comment. In our comment, we 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 this comment, we may have additional comments. Form 10-K for the Year Ended December 31, 2019 Note 11. Income Taxes , page 84 1.Please provide additional context disclosing why the decrease in the tax valuation allowance was recorded through equity and advise us. Explain to us the nature of this adjustment and your basis for recording it under GAAP. Also tell us how you recorded the adjustment in your financial statements and why it does not appear on your Consolidated Statements of Stockholders' Equity.
FirstName LastNameMark Partin Comapany NameBlackline, Inc. April 22, 2020 Page 2 FirstName LastName Mark Partin Blackline, Inc. April 22, 2020 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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology
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April 22, 2020
Mark Partin
Chief Financial Officer
Blackline, Inc.
21300 Victory Boulevard, 12th Floor
Woodland Hills, CA 91367
Re:Blackline, Inc.
Form 10-K for the Year Ended December 31, 2019
Filed February 27, 2020
File No. 001-37924
Dear Mr. Partin:
We have reviewed your filing and have the following comment. In our comment, we 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 this comment, we may have additional comments.
Form 10-K for the Year Ended December 31, 2019
Note 11. Income Taxes , page 84
1.Please provide additional context disclosing why the decrease in the tax valuation
allowance was recorded through equity and advise us. Explain to us the nature of this
adjustment and your basis for recording it under GAAP. Also tell us how you recorded
the adjustment in your financial statements and why it does not appear on your
Consolidated Statements of Stockholders' Equity.
FirstName LastNameMark Partin
Comapany NameBlackline, Inc.
April 22, 2020 Page 2
FirstName LastName
Mark Partin
Blackline, Inc.
April 22, 2020
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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or
Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology