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UPLOAD Filing

Coupang, Inc.
Date: June 26, 2025 · CIK: 0001834584 · Accession: 0000000000-25-006746

Financial Reporting Internal Controls Regulatory Compliance

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File numbers found in text: 001-40115

Date
June 26, 2025
Author
Division of
Form
UPLOAD
Company
Coupang, Inc.

Letter

Re: Coupang, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 File No. 001-40115 Dear Gaurav Anand:

June 26, 2025

Gaurav Anand Chief Financial Officer Coupang, Inc. 720 Olive Way, Suite 600 Seattle, Washington 98101

We have reviewed your filing 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 10-K for Fiscal Year Ended December 31, 2024 Consolidated Financial Statements Notes to Consolidated Financial Statements 3. Segment Reporting, page 72

1. Please tell us how your disclosure complies with the requirement to disclose how the chief operating decision maker uses your reported measure of segment profit or loss in assessing segment performance and deciding how to allocate resources pursuant to ASC 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance. 2. Please tell us how you considered whether costs included in operating, general and administrative expenses were significant segment expenses in accordance with ASC 280-10-50-26A, or other segment items in accordance with ASC 280-10-50-26B.

In defining segment adjusted EBITDA, you state other segment items in reconciling from net revenues by segment to Segment Adjusted EBITDA include cost of sales, operating, general and administrative expense, and the adjustments described below." However, it appears from the table on page 73 that cost of sales is a significant segment expense. Please advise. After considering the points above, please also revise June 26, 2025 Page 2

to present any costs included in Segment Adjusted EBITDA that are not deemed significant segment expenses as other segment items on a segment basis. 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 Amy Geddes at 202-551-3304 or Abe Friedman at 202-551-8298 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 June 26, 2025

Gaurav Anand
Chief Financial Officer
Coupang, Inc.
720 Olive Way, Suite 600
Seattle, Washington 98101

 Re: Coupang, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-40115
Dear Gaurav Anand:

 We have reviewed your filing 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 10-K for Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Notes to Consolidated Financial Statements
3. Segment Reporting, page 72

1. Please tell us how your disclosure complies with the requirement to
disclose how the
 chief operating decision maker uses your reported measure of segment
profit or loss in
 assessing segment performance and deciding how to allocate resources
pursuant to
 ASC 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance.
2. Please tell us how you considered whether costs included in
operating, general and
 administrative expenses were significant segment expenses in
accordance with ASC
 280-10-50-26A, or other segment items in accordance with ASC
280-10-50-26B.

 In defining segment adjusted EBITDA, you state other segment items in
reconciling
 from net revenues by segment to Segment Adjusted EBITDA include cost of
sales,
 operating, general and administrative expense, and the adjustments
described below."
 However, it appears from the table on page 73 that cost of sales is a
significant
 segment expense. Please advise. After considering the points above,
please also revise
 June 26, 2025
Page 2

 to present any costs included in Segment Adjusted EBITDA that are not
deemed
 significant segment expenses as other segment items on a segment basis.
 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 Amy Geddes at 202-551-3304 or Abe Friedman at
202-551-8298 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>