SEC Comment Letter 0000000000-23-001824 to Elastic N.V. (ESTC) (CIK 0001707753) (ESTC)
Elastic N.V. (ESTC) (CIK 0001707753)
Date: Feb. 23, 2023 · CIK: 0001707753 · Accession: 0000000000-23-001824
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38675
Letter
United States securities and exchange commission logo February 23, 2023 Janesh Moorjani Chief Financial Officer Elastic N.V. 800 West El Camino Real, Suite 350 Mount View, CA 94040 Re:Elastic N.V. Form 10-K for the Fiscal Year ended April 30, 2022 Filed June 21, 2022 File No. 001-38675 Dear Janesh Moorjani: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 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 Fiscal Year ended April 30, 2022 Management’s Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies and Estimates Revenue Recognition, page 66 1.We note the second risk factor disclosure on page 35 explaining that you are dependent upon lead generation strategies, including offering free use of some of your product features and free trials of some of your paid features.
You also have disclosures under Our Growth Strategies on page 6, indicating that you plan to expand your customer base by acquiring new customers, and that one of the easiest ways to acquire customers is by offering free trials; also under Key Factors Affecting Our Performance on page 55, stating that your financial performance depends on growing your paid customer base by converting free users of your software into paid subscribers.
FirstName LastNameJanesh Moorjani Comapany NameElastic N.V. February 23, 2023 Page 2 FirstName LastName Janesh Moorjani Elastic N.V. February 23, 2023 Page 2 Please expand your disclosure on page 66 to describe the accounting policy applied in determining when free product features or trials would be sales incentives and when free product features or trials would be part of a contract with a customer, if the customer becomes a paid subscriber before the free service or free trial period ends.
Also discuss any assumptions and uncertainties involved in the application of that policy consistent with the guidance in Section V of SEC Release No. 33-8350. 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. You may contact Yong Kim, Staff Accountant, at 202-551-3323 or Gus Rodriguez, Staff Accountant, at 202-551-3752 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
February 23, 2023
Janesh Moorjani
Chief Financial Officer
Elastic N.V.
800 West El Camino Real, Suite 350
Mount View, CA 94040
Re:Elastic N.V.
Form 10-K for the Fiscal Year ended April 30, 2022
Filed June 21, 2022
File No. 001-38675
Dear Janesh Moorjani:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. 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 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 Fiscal Year ended April 30, 2022
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates
Revenue Recognition, page 66
1.We note the second risk factor disclosure on page 35 explaining that you are dependent
upon lead generation strategies, including offering free use of some of your product
features and free trials of some of your paid features.
You also have disclosures under Our Growth Strategies on page 6, indicating that you
plan to expand your customer base by acquiring new customers, and that one of the easiest
ways to acquire customers is by offering free trials; also under Key Factors Affecting Our
Performance on page 55, stating that your financial performance depends on growing your
paid customer base by converting free users of your software into paid subscribers.
FirstName LastNameJanesh Moorjani
Comapany NameElastic N.V.
February 23, 2023 Page 2
FirstName LastName
Janesh Moorjani
Elastic N.V.
February 23, 2023
Page 2
Please expand your disclosure on page 66 to describe the accounting policy applied in
determining when free product features or trials would be sales incentives and when free
product features or trials would be part of a contract with a customer, if the customer
becomes a paid subscriber before the free service or free trial period ends.
Also discuss any assumptions and uncertainties involved in the application of that policy
consistent with the guidance in Section V of SEC Release No. 33-8350.
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.
You may contact Yong Kim, Staff Accountant, at 202-551-3323 or Gus Rodriguez, Staff
Accountant, at 202-551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation