Pillsbury Winthrop Shaw Pittman LLP 31 West 52nd Street | New York, NY 10019-6131 | tel 212.858.1000 | fax 212.858.1500 |
David Ingles tel: +1.212.858.1231 david.ingles@pillsburylaw.com |
VIA EDGAR
July 16, 2021
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attn: | Rebekah Lindsey, Senior Staff Accountant |
Kathleen Collins, Accounting Branch Chief
Re: | Support.com, Inc. |
Form 10-K for Fiscal Year Ended December 31, 2020 |
Filed March 30, 2021 |
File No. 001-37594 |
Ladies and Gentlemen:
On behalf of Support.com, Inc. (the “Company”), we are providing this letter in response to the comments of the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) contained in its letter dated July 12, 2021 (the “Comment Letter”), relating to the Form 10-K for Fiscal Year Ended December 31, 2020, filed on March 30, 2021 (the “Form 10-K”).
For the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company.
Form 10-K for the fiscal year ended December 31, 2020
Management’s Discussion and Analysis of Financial Condition and Results of Operations Revenue, page 28
1. | We note your response to our prior comment 1. Please amend your filings to provide the more specific information regarding the decline in business from Comcast as provided in your response. Further, please also include the total revenue recognized during the period from Comcast, as well as the amount of historical revenue related to the business unit and Statement of Work #3 in a manner similar to that provided in your Forms 8-K. |
U.S. Securities and Exchange Commission
July 16, 2021
Page 2
Response: In response to the Staff’s comments, the disclosure on page 2 has been revised to provide additional information regarding Comcast and our decline in revenue during the periods presented.
Consolidated Financial Statements
Note 1. Organization and Summary of Significant Accounting Policies
Segment Information, page 50
2. | We note your response to our prior comment 2. Please amend your filing to separately disclose the amount of revenue from each of your major customers for each period presented. |
Response: In response to the Staff’s comments, the disclosure on page 24 has been revised to include the amount of revenue from each of our customers that accounted for 10% or more of our total revenue in each period presented.
*****
Please contact the undersigned at (212) 858-1231 or david.ingles@pillsburylaw.com with any questions regarding the responses to the Staff’s comments. Thank you in advance for your attention to this matter.
Sincerely,
/s/ David Ingles
David Ingles
cc: | Lance Rosenzweig, Chief Executive Officer of Support.com, Inc. |
Kathleen Krebs, Special Counsel, U.S. Securities and Exchange Commission |