SEC Comment Letter for DoorDash, (DASH) — May 19, 2022
DoorDash, Inc.
Date: May 19, 2022 · CIK: 0001792789 · Accession: 0000000000-22-005549
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File numbers found in text: 001-39759
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United States securities and exchange commission logo
May 19, 2022
Prabir Adarkar
Chief Financial Officer
DoorDash, Inc.
303 2nd Street, South Tower, 8th Floor
San Francisco, California 94107
Re:DoorDash, Inc.
Form 10-K for the Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-39759
Dear Mr. Adarkar:
We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2021
Key Business and Non-GAAP Metrics, page 66
1.Please revise your presentation to present the most comparable GAAP measures for
Contribution Profit and Adjusted EBITDA with equal or greater prominence in both your
table and your discussion presented here. Refer to the guidance in Item 10(e)(1)(i)(A) of
Regulation S-K and Question 102.10 of the Compliance and Disclosure Interpretations on
Non-GAAP Measures.
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 72
2.We note that all of your Non-GAAP measures presented here, except for Adjusted
EBITDA, include an adjustment for "Allocated Overhead." Overhead appears to
include normal, recurring, cash operating expenses necessary to operate your business.
Please tell us why you believe these adjustments are permitted under Rule 100(b) of
FirstName LastNamePrabir Adarkar
Comapany NameDoorDash, Inc.
May 19, 2022 Page 2
FirstName LastName
Prabir Adarkar
DoorDash, Inc.
May 19, 2022
Page 2
Regulation G. Refer to Question 100.01 of the Compliance and Disclosure Interpretations
on Non-GAAP Measures.
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 Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services