SEC Comment Letter for Jamf Holding Corp. (JAMF) (CIK 0001721947) — Apr 15, 2022
Jamf Holding Corp. (JAMF) (CIK 0001721947)
Date: April 15, 2022 · CIK: 0001721947 · Accession: 0000000000-22-004087
AI Filing Summary & Sentiment
File numbers found in text: 001-39399
Letter
United States securities and exchange commission logo April 15, 2022 Jill Putman Chief Financial Officer Jamf Holding Corp. 100 Washington Ave S, Suite 1100 Minneapolis, MN 55401 Re:Jamf Holding Corp. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed March 1, 2022 File No. 001-39399 Dear Ms. Putman: We have reviewed your April 4, 2022 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 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. Unless we note otherwise, our references to prior comments are to comments in our March 25, 2022 letter. Form 10-K for the Fiscal Year Ended December 31, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 79 1.We note your response to prior comment 2 and it remains unclear how your non-GAAP tax rate is consistent with the guidance in Question 102.11 of the Non-GAAP C&DIs. As previously noted, the tax adjustment should include tax expense commensurate with your non-GAAP measure of profitability. You appear to have reported cumulative non- GAAP net income before taxes in recent years, which suggests that from a non- GAAP perspective, loss carryforwards may not be available nor would a valuation allowance be warranted and therefore should not be considered in determining your non- GAAP income tax adjustment. Please further explain how your non-GAAP tax rate is consistent with Question 102.11 or revise.
FirstName LastNameJill Putman Comapany NameJamf Holding Corp. April 15, 2022 Page 2 FirstName LastName Jill Putman Jamf Holding Corp. April 15, 2022 Page 2 You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or Christine Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
April 15, 2022
Jill Putman
Chief Financial Officer
Jamf Holding Corp.
100 Washington Ave S, Suite 1100
Minneapolis, MN 55401
Re:Jamf Holding Corp.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-39399
Dear Ms. Putman:
We have reviewed your April 4, 2022 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 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.
Unless we note otherwise, our references to prior comments are to comments in our March 25,
2022 letter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 79
1.We note your response to prior comment 2 and it remains unclear how your non-GAAP
tax rate is consistent with the guidance in Question 102.11 of the Non-GAAP C&DIs. As
previously noted, the tax adjustment should include tax expense commensurate with
your non-GAAP measure of profitability. You appear to have reported cumulative non-
GAAP net income before taxes in recent years, which suggests that from a non-
GAAP perspective, loss carryforwards may not be available nor would a valuation
allowance be warranted and therefore should not be considered in determining your non-
GAAP income tax adjustment. Please further explain how your non-GAAP tax rate is
consistent with Question 102.11 or revise.
FirstName LastNameJill Putman
Comapany NameJamf Holding Corp.
April 15, 2022 Page 2
FirstName LastName
Jill Putman
Jamf Holding Corp.
April 15, 2022
Page 2
You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology