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June 4, 2024
Mansi Khetani
Interim Chief Financial Officer
ChargePoint Holdings, Inc.
240 East Hacienda Avenue
Campbell, CA 95008
Re:ChargePoint Holdings, Inc.
Form 10-K for the Fiscal Year Ended January 31, 2024
Filed April 1, 2024
Form 8-K Furnished March 5, 2024
File No. 001-39004
Dear Mansi Khetani:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 8-K Furnished March 5, 2024
Exhibit 99.1, page 8
1.We note your disclosure of non-GAAP gross profit and non-GAAP gross margin under
the reconciliation of non-GAAP cost of revenue. However, we do not note disclosure of
GAAP gross profit or margin in the table or a reconciliation of this non-GAAP measure to
the comparable GAAP measure. We also note your disclosure of non-GAAP operating
expenses, which represent the sum of non-GAAP research and development, non-GAAP
sales and marketing, and non-GAAP general and administrative, in addition to the non-
GAAP operating expenses as a percentage of revenue. Please revise future filings to
present a reconciliation of the non-GAAP financial measures to the most directly
comparable GAAP measures in compliance with Item 10(e)(1)(i)(B) of Regulation S-X in
future filings.
2.We note you present the following non-GAAP financial measures without presenting the

 FirstName LastNameMansi Khetani
 Comapany NameChargePoint Holdings, Inc.
 June 4, 2024 Page 2
 FirstName LastNameMansi Khetani
ChargePoint Holdings, Inc.
June 4, 2024
Page 2
most directly comparable GAAP measures with equal or greater prominence:
•Non-GAAP research and development as a percentage of revenue
•Non-GAAP sales and marketing as a percentage of revenue
•Non-GAAP general and administrative as a percentage of revenue
•Non-GAAP net loss as a percentage of revenue
•Non-GAAP pre-tax net loss as a percentage of revenue
•Non-GAAP adjusted EBITDA loss as a percentage of revenue
Please present the most directly comparable GAAP measure with equal or greater
prominence whenever a non-GAAP financial measure is presented. Refer to Question
102.10(a) of the Division of Corporation Finance’s Compliance & Disclosure
Interpretations on Non-GAAP Financial Measures.

In addition, revise your future other public disclosures, such as investor presentations, to
present the most directly comparable GAAP measures whenever non-GAAP measures are
presented. See Rule 100(a)(1) of Regulation G.
Form 10-K for the Fiscal Year Ended January 31, 2024
Notes to Consolidated Financial Statements, page 74
3.We note your disclosures of disaggregated revenues by geographic area on page 100 and
revenue line (networked charging systems, subscriptions, and other) on your consolidated
statements of operations. Please tell us how you considered the guidance to further
disaggregate revenue into categories that depict how the nature, amount, timing, and
uncertainty of revenue and cash flows are affected by economic factors, e.g., type of
customer (vertical), product type, and sales channel. Refer to ASC 606-10-50-5 and also
see ASC 606-10-55-89 through 91.  In this regard, we note from your disclosure in
MD&A that the AC charger based commercial business contributes higher margins than
its residential and DC charger based fleet businesses and we note from the earnings calls
that you disclose billings percentages (which approximate revenue split) for commercial,
fleet, residential and other. Please advise or revise as appropriate.
2. Summary of Significant Accounting Policies
Revenue Recognition
Networked Charging Systems revenue, page 81
4.We note your disclosure that the Company recognizes revenue from sales of Networked
Charging Systems upon shipment to the customer. Please explain to us if the customer you
refer to in your disclosures in Note 2 is the same as the end users described on pages 8 and
19. We also note your disclosure on page 19 that the majority of your products are sold
through your channel partners, distributors, and resellers. In this regard, if revenue
recognition process is not complete at the time the channel partner takes delivery of the
shipment, identify the nature of any remaining obligations, or risks or rewards that have
not yet transferred to the channel partner at the time they accept delivery of the shipments.
Refer to guidance in ASC 606-10-25-30 and ASC 606-10-50-12.

 FirstName LastNameMansi Khetani
 Comapany NameChargePoint Holdings, Inc.
 June 4, 2024 Page 3
 FirstName LastName
Mansi Khetani
ChargePoint Holdings, Inc.
June 4, 2024
Page 3
Note 2. Summary of Significant Accounting Policies
Warranty, page 84
5.We note your disclosure on page 84 that you provide a standard warranty coverage on
your products, providing parts necessary to repair the systems during the warranty period,
and that warranty expense for the years ended January 31, 2024, 2023, and 2022 was
$16.7 million, $5.4 million, and $3.8 million, respectively.  Please provide for us and
revise to provide the disclosures required by ASC 460-10-50-8.
            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.
            Please contact Stephany Yang at 202-551-3167 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing