SEC Comment Letter 0000000000-22-012806 to Reddit, Inc. (RDDT) (CIK 0001713445) (RDDT)
Reddit, Inc. (RDDT) (CIK 0001713445)
Date: Nov. 28, 2022 · CIK: 0001713445 · Accession: 0000000000-22-012806
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United States securities and exchange commission logo November 28, 2022 Steven Huffman Chief Executive Officer Reddit, Inc. 1455 Market Street, Suite 1600 San Francisco, California 94103 Re:Reddit, Inc. Amendment No. 6 to Draft Registration Statement on Form S-1 Submitted November 16, 2022 CIK No. 0001713445 Dear Steven Huffman: 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. Amendment No. 6 to Draft Registration Statement on Form S-1 submitted November 16, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Key Financial and Operating Metrics, page 98 1.On page 100, you disclose that subsequent to September 30, 2022, you began to deploy further advances in your process used to identify and address accounts, including bots, that you believe violate your policies. Please revise to clarify whether you will recalculate your metrics for prior periods using this revised process and whether this revised process has identified a material number of accounts in violation of your policies.
FirstName LastNameSteven Huffman Comapany NameReddit, Inc. November 28, 2022 Page 2 FirstName LastName Steven Huffman Reddit, Inc. November 28, 2022 Page 2 Financial Statements Note 17 - Subsequent events, page F-62 2.We note on pages 122 and 123 that the most recent third party valuation is as of August 4, 2022. We also note on page F-62 that you granted additional RSUs on November 3, 2022 and the "valuation will be determined". Please revise the disclosure to include the November 3, 2022 valuation when it is completed and expand the disclosures to include the amount of unrecognized stock compensation expense on November 3, 2022 RSU grant. You may contact Claire DeLabar, Senior Staff Accountant, at (202) 551-3349 or Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or Joshua Shainess, Legal Branch Chief, at (202) 551-7951 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Sarah Axtell, Esq.
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United States securities and exchange commission logo
November 28, 2022
Steven Huffman
Chief Executive Officer
Reddit, Inc.
1455 Market Street, Suite 1600
San Francisco, California 94103
Re:Reddit, Inc.
Amendment No. 6 to Draft Registration Statement on Form S-1
Submitted November 16, 2022
CIK No. 0001713445
Dear Steven Huffman:
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.
Amendment No. 6 to Draft Registration Statement on Form S-1 submitted November 16, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Financial and Operating Metrics, page 98
1.On page 100, you disclose that subsequent to September 30, 2022, you began to deploy
further advances in your process used to identify and address accounts, including bots,
that you believe violate your policies. Please revise to clarify whether you will recalculate
your metrics for prior periods using this revised process and whether this revised process
has identified a material number of accounts in violation of your policies.
FirstName LastNameSteven Huffman
Comapany NameReddit, Inc.
November 28, 2022 Page 2
FirstName LastName
Steven Huffman
Reddit, Inc.
November 28, 2022
Page 2
Financial Statements
Note 17 - Subsequent events, page F-62
2.We note on pages 122 and 123 that the most recent third party valuation is as of August 4,
2022. We also note on page F-62 that you granted additional RSUs on November 3, 2022
and the "valuation will be determined". Please revise the disclosure to include the
November 3, 2022 valuation when it is completed and expand the disclosures to include
the amount of unrecognized stock compensation expense on November 3, 2022 RSU
grant.
You may contact Claire DeLabar, Senior Staff Accountant, at (202) 551-3349 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact Mitchell Austin, Staff
Attorney, at (202) 551-3574 or Joshua Shainess, Legal Branch Chief, at (202) 551-7951 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Sarah Axtell, Esq.