SEC Comment Letter for Opendoor Technologies Inc. (OPEN) (CIK 0001801169) (OPEN) — Mar 6, 2020
Opendoor Technologies Inc. (OPEN) (CIK 0001801169)
Date: March 6, 2020 · CIK: 0001801169 · Accession: 0000000000-20-002049
AI Filing Summary & Sentiment
File numbers found in text: 333-236774
Letter
March 5, 2020 Chamath Palihapitiya Chief Executive Officer Social Capital Hedosophia Holdings Corp. II 317 University Ave, Suite 200 Palo Alto, CA 94301 Re:Social Capital Hedosophia Holdings Corp. II Registration Statement on Form S-1 Filed February 28, 2020 File No. 333-236774 Dear Mr. Palihapitiya: We have reviewed your registration statement 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 letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Form S-1 Financial Statements, page F-1 1.We note your response to our prior comment 1. Please revise to include the unaudited financial information in a subsequent event footnote as we continue to question why unaudited interim financial statements through January 21, 2020 are appropriate. 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
FirstName LastNameChamath Palihapitiya Comapany NameSocial Capital Hedosophia Holdings Corp. II March 5, 2020 Page 2 FirstName LastName Chamath Palihapitiya Social Capital Hedosophia Holdings Corp. II March 5, 2020 Page 2 You may contact Paul Cline at 202-551-3851 or Wilson Lee at 202-551-3468 if you have questions regarding comments on the financial statements and related matters. Please contact Ronald (Ron) Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Gregg A. Noel
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March 5, 2020
Chamath Palihapitiya
Chief Executive Officer
Social Capital Hedosophia Holdings Corp. II
317 University Ave, Suite 200
Palo Alto, CA 94301
Re:Social Capital Hedosophia Holdings Corp. II
Registration Statement on Form S-1
Filed February 28, 2020
File No. 333-236774
Dear Mr. Palihapitiya:
We have reviewed your registration statement 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 letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Form S-1
Financial Statements, page F-1
1.We note your response to our prior comment 1. Please revise to include the unaudited
financial information in a subsequent event footnote as we continue to question why
unaudited interim financial statements through January 21, 2020 are appropriate.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
FirstName LastNameChamath Palihapitiya
Comapany NameSocial Capital Hedosophia Holdings Corp. II
March 5, 2020 Page 2
FirstName LastName
Chamath Palihapitiya
Social Capital Hedosophia Holdings Corp. II
March 5, 2020
Page 2
You may contact Paul Cline at 202-551-3851 or Wilson Lee at 202-551-3468 if you have
questions regarding comments on the financial statements and related matters. Please contact
Ronald (Ron) Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Gregg A. Noel