SEC Comment Letter for SIMILARWEB LTD. (SMWB) (CIK 0001842731) (SMWB) — Sep 8, 2025
SIMILARWEB LTD. (SMWB) (CIK 0001842731)
Date: Sept. 8, 2025 · CIK: 0001842731 · Accession: 0000000000-25-009682
AI Filing Summary & Sentiment
File numbers found in text: 001-40394
Letter
September 8, 2025 Jason Schwartz Chief Financial Officer Similarweb Ltd. 33 Yitzhak Rabin Rd. Givatayim 5348303, Israel Re:Similarweb Ltd. Form 20-F for the Fiscal Year Ended December 31, 2024 Filed February 27, 2025 File No. 001-40394 Dear Jason Schwartz: We have reviewed your filing 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 the 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 20-F for the Fiscal Year Ended December 31, 2024 Operating and Financial Review and Prospects Key Factors Affecting Our Performance, page 78 We note you use Annual Recurring Revenue (ARR) as a key business metric to evaluate further sales expansion of subscription revenues. Please expand your disclosure to address the following and advise us. •Explain how multi-year contracts are factored into your calculations and the typical terms of such arrangements. •Clarify how ARR reflects new and existing customers and any actual or anticipated reductions of revenue due to contract non-renewals or cancellations, and discuss any limitations present as a result. •Disclose the renewal rates for subscription arrangements for each period presented to support your assumptions. •Describe how ARR differs from GAAP revenue. Disclose whether ARR is indicative of future revenue and if not, how it may •1.
September 8, 2025 Page 2 differ. 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 Joseph Cascarano at 202-551-3376 or Robert Littlepage at 202-551- 3361 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology
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September 8, 2025
Jason Schwartz
Chief Financial Officer
Similarweb Ltd.
33 Yitzhak Rabin Rd.
Givatayim 5348303, Israel
Re:Similarweb Ltd.
Form 20-F for the Fiscal Year Ended December 31, 2024
Filed February 27, 2025
File No. 001-40394
Dear Jason Schwartz:
We have reviewed your filing 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
the 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 20-F for the Fiscal Year Ended December 31, 2024
Operating and Financial Review and Prospects
Key Factors Affecting Our Performance, page 78
We note you use Annual Recurring Revenue (ARR) as a key business metric to
evaluate further sales expansion of subscription revenues. Please expand your
disclosure to address the following and advise us.
•Explain how multi-year contracts are factored into your calculations and the
typical terms of such arrangements.
•Clarify how ARR reflects new and existing customers and any actual or
anticipated reductions of revenue due to contract non-renewals or cancellations,
and discuss any limitations present as a result.
•Disclose the renewal rates for subscription arrangements for each period
presented to support your assumptions.
•Describe how ARR differs from GAAP revenue.
Disclose whether ARR is indicative of future revenue and if not, how it may •1.
September 8, 2025
Page 2
differ.
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 Joseph Cascarano at 202-551-3376 or Robert Littlepage at 202-551-
3361 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation Finance
Office of Technology