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United States securities and exchange commission logo
November 17, 2022
Rathna Girish Mathrubootham
Chief Executive Officer
Freshworks Inc.
2950 S. Delaware Street, Suite 201
San Mateo, CA 94403
Re: Freshworks Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 23,
2022
File No. 001-40806
Dear Rathna Girish Mathrubootham:
We have reviewed your filing 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 Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Key Business Metrics, page 50
1. We note that you
continue to provide the number of customers contributing more then
$5,000 in ARR as a key
business metric. Please revise to disclose the percentage of ARR
attributable to these
customers for each period presented to provide context to such
measure. We refer you
to comment 12 in your June 25, 2021 response letter. Also, tell us
your consideration to
include the number of such customers and the percentage growth in
ARR related to such
customers for each period for which a statement of operations is
presented.
2. Please tell us whether
you continue to include monthly subscriptions in your calculation of
net dollar retention
rate. If so, revise to include a discussion of how monthly subscriptions
factor into such
calculations and how ARR and net dollar retention rates may be impacted
Rathna Girish Mathrubootham
Freshworks Inc.
November 17, 2022
Page 2
if such contracts are not renewed. Lastly, disclose the percentage of ARR
from monthly
subscriptions for each period presented. We refer to you to comment 7 in
your July 19,
2021 response letter.
Results of Operations, page 54
3. You attribute the increase in revenue for fiscal 2021 compared to 2020 to
increases in
additional agents enabled by your customers, sales to existing customers
and the addition
of new customers. Where a material changes from period-to-period is due
to two or more
factors, including any offsetting factors, revise to describe the
underlying reasons for these
material changes in both quantitative and qualitative terms. Refer to
Item 303(b) of
Regulation S-K.
Item 8. Financial Statements and Supplementary Data
Note 14. Geographic Information, page 96
4. We note that you generate a significant amount of revenue from
international operations.
Please tell us whether North America is comprised of only the United
States. If not,
revise to disclose revenue from your country of domicile separately from
all other
countries. Also, tell us whether revenue from any individual country is
material and if so,
how you considered the guidance in ASC 280-10-50-41(a) to disclose such
revenue.
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 Megan Akst, Senior Staff Accountant at 202-551-3407 or
Kathleen
Collins, Accounting Brach Chief at 202-551-3499 if you have questions.
Sincerely,
FirstName LastNameRathna Girish Mathrubootham
Division of
Corporation Finance
Comapany NameFreshworks Inc.
Office of
Technology
November 17, 2022 Page 2
cc: Jon Avina
FirstName LastName