SEC Comment Letter 0000000000-24-010380 to Taboola.com Ltd. (TBLA, TBLAW) (CIK 0001840502) (TBLA)
Taboola.com Ltd. (TBLA, TBLAW) (CIK 0001840502)
Date: Sept. 13, 2024 · CIK: 0001840502 · Accession: 0000000000-24-010380
AI Filing Summary & Sentiment
File numbers found in text: 001-40566
Letter
September 13, 2024 Stephen Walker Chief Financial Officer Taboola.com Ltd. 16 Madison Square West 7th Floor New York, NY 10010 Re:Taboola.com Ltd. Form 10-K for the Year Ended December 31, 2023 Filed February 28, 2024 Form 10-Q for the Quarter Ended June 30, 2024 Filed August 7, 2024 File Number 001-40566 Dear Stephen Walker: We have limited our review of your filings to the financial statements and related disclosures and have the following comment. 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 our 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-Q For the Quarterly Period Ended June 30, 2024 Notes to the Consolidated Interim Financial Statements Note 1. General, page 11 1.We note in MD&A "[n]ew digital property partners contributed approximately $103.7 million of new Revenues on a 12-month run rate basis calculated based on their first full month on the network, a majority of which is related to Yahoo supply." In light of your recognition of revenue in connection with the Yahoo Commercial agreement, explain to us your basis for not reporting amortization of the Commercial agreement asset as an expense associated with the revenue in 2023 and 2024. Refer us to the accounting literature that supports your policy. In closing, we remind you that the company and its management are responsible for the
September 13, 2024 Page 2 accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Joseph Kempf at 202-551-3352 or Robert Littlepage at 202-551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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September 13, 2024
Stephen Walker
Chief Financial Officer
Taboola.com Ltd.
16 Madison Square West
7th Floor
New York, NY 10010
Re:Taboola.com Ltd.
Form 10-K for the Year Ended December 31, 2023
Filed February 28, 2024
Form 10-Q for the Quarter Ended June 30, 2024
Filed August 7, 2024
File Number 001-40566
Dear Stephen Walker:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comment.
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
our 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-Q For the Quarterly Period Ended June 30, 2024
Notes to the Consolidated Interim Financial Statements
Note 1. General, page 11
1.We note in MD&A "[n]ew digital property partners contributed approximately $103.7
million of new Revenues on a 12-month run rate basis calculated based on their first full
month on the network, a majority of which is related to Yahoo supply." In light of your
recognition of revenue in connection with the Yahoo Commercial agreement, explain to
us your basis for not reporting amortization of the Commercial agreement asset as an
expense associated with the revenue in 2023 and 2024. Refer us to the accounting
literature that supports your policy.
In closing, we remind you that the company and its management are responsible for the
September 13, 2024
Page 2
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Joseph Kempf at 202-551-3352 or Robert Littlepage at 202-551-3361 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology