SEC Comment Letter for Talend S.A. (CIK 0001668105) — Jan 9, 2020
Talend S.A. (CIK 0001668105)
Date: Jan. 9, 2020 · CIK: 0001668105 · Accession: 0000000000-20-000216
AI Filing Summary & Sentiment
File numbers found in text: 001-37825
Letter
January 8, 2020 Michael Tuchen Chief Executive Officer Talend S.A. 9, rue Pages Suresnes, France Re:Talend S.A. Form 10-K for the fiscal year ended December 31, 2018 Filed February 28, 2019 File No. 001-37825 Dear Mr. Tuchen: We have reviewed your December 11, 2019 response to our comment letter 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 the 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. Unless we note otherwise, our references to prior comments are to comments in our December 2, 2019 letter. Form 10-K for the fiscal year ended December 31, 2018 Note 2. Summary of Significant Accounting Policies (e) Revenue Recognition Allocation of the transaction price to the performance obligations in the contract, page 83 1.We note your response to prior comment 1. Please tell us the specific costs that directly relate to “providing” the IP and tell us what consideration was given to including the costs incurred to develop the IP. As part of your response, tell us what consideration was given to using the “adjusted market assessment approach” to estimate SSP for the performance obligations. Refer to ASC 606-10-32-34a.
FirstName LastNameMichael Tuchen Comapany NameTalend S.A. January 8, 2020 Page 2 FirstName LastName Michael Tuchen Talend S.A. January 8, 2020 Page 2 You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology
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January 8, 2020
Michael Tuchen
Chief Executive Officer
Talend S.A.
9, rue Pages
Suresnes, France
Re:Talend S.A.
Form 10-K for the fiscal year ended December 31, 2018
Filed February 28, 2019
File No. 001-37825
Dear Mr. Tuchen:
We have reviewed your December 11, 2019 response to our comment letter 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 the 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. Unless we note otherwise, our references to prior comments are to comments in our
December 2, 2019 letter.
Form 10-K for the fiscal year ended December 31, 2018
Note 2. Summary of Significant Accounting Policies
(e) Revenue Recognition
Allocation of the transaction price to the performance obligations in the contract, page 83
1.We note your response to prior comment 1. Please tell us the specific costs that directly
relate to “providing” the IP and tell us what consideration was given to including the costs
incurred to develop the IP. As part of your response, tell us what consideration was given
to using the “adjusted market assessment approach” to estimate SSP for the performance
obligations. Refer to ASC 606-10-32-34a.
FirstName LastNameMichael Tuchen
Comapany NameTalend S.A.
January 8, 2020 Page 2
FirstName LastName
Michael Tuchen
Talend S.A.
January 8, 2020
Page 2
You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Christine Dietz,
Senior Staff Accountant, at (202) 551-3408 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology