Uber Technologies, Inc — Regulatory Filings 2021

Apr 6, 2021

CORRESP 1 filename1.htm html PUBLIC "-//W3C//DTD HTML 4.01 Transitional//EN" "http://www.w3.org/TR/html4/loose.dtd" Document created using Wdesk Copyright 2021 Workiva Document

UBER TECHNOLOGIES, INC. 1515 3rd STREET SAN FRANCISCO, CA 94158 UBER.COM

April 6, 2021

VIA EDGAR AND ELECTRONIC MAIL

U.S. Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services

100 F Street, NE Washington, DC 20549

Attn: Scott Stringer

Linda Cvrkel

Re: Uber Technologies, Inc. Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2020 Filed March 1, 2021 File No. 1-38902

Ladies and Gentlemen:

Uber Technologies, Inc. (the “ Company ”, “ we ”, “ our ”) is submitting this letter in response to a letter, dated March 25, 2021, from the staff of the Division of Corporation Finance (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ Commission ”) with respect to the Company’s Annual Report on Form 10-K filed with the Commission on March 1, 2021.

The numbering of the paragraph below corresponds to the numbering of the comment in the letter from the Staff. For the Staff’s convenience, we have incorporated the text of the Staff’s comment into this response letter in italics.

In addition to submitting this letter via EDGAR, we are sending a copy of this letter via electronic mail.

Form 10-K for the Fiscal Year Ended December 31, 2020

Notes to Consolidated Financial Statements

Note 1 - Description of Business and Summary of Significant Accounting Policies

Revenue Recognition, page 99

1. We note you have a membership or “Pass” program allowing users to unlock savings across platforms for a monthly fee. Please explain the significance of this program and your consideration of disclosing your accounting policy with regards to revenue recognition. Also, please explain how you allocate membership revenue across the segments offering this program.

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

April 6, 2021

Page 2

Response to Comment No. 1: The Company acknowledges the Staff’s comment and respectfully advises the Staff that revenue generated from membership or “Pass” programs was not material to our financial statements for the years ended December 31, 2020, 2019 or 2018; and therefore, we did not include specific accounting policy disclosure related to these programs. The Company will continue to monitor these programs and include future accounting policy disclosures if they become material.

The Company allocates revenue generated from any “Pass” program that offers savings across segments on a proportional basis, based on usage for each segment during the related period.

---

Please contact me or Keir Gumbs using the contact information previously provided with any questions or further comments regarding our responses to the Staff’s comment.

Sincerely,
/s/ Nelson Chai
Nelson Chai
Uber Technologies, Inc.

cc: Tony West, Senior Vice President, Chief Legal Officer and Corporate Secretary