August 14, 2024
Gaurav Anand
Chief Financial Officer
Coupang, Inc.
720 Olive Way, Suite 600
Seattle, Washington 98101
Re: Coupang, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-40115
Dear Gaurav Anand:
We have reviewed your filing and have the following comments.
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 a
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-K for Fiscal Year Ended December 31, 2023
Item 7. Management s Discussion and Analysis of Financial Condition and
Results of Operations
Non-GAAP Financial Measures, page 45
1. Please present your non-GAAP financial measures after your discussion of
historical
results of operations. Refer to Item 10(e)(i)(A) of Regulation S-K and
Question 102.10 of
the "Non-GAAP Financial Measures" Compliance and Disclosure
Interpretations for
guidance.
Results of Operations, page 47
2. Where you attribute material fluctuations in your results to multiple
factors,
please quantify each factor cited so investors may understand the
magnitude and relative
impact of each factor. As an example, you cite multiple factors which
caused increases to
your Product Commerce net revenues with specific reference to the impact
of
the transition of FLC merchants to new contracts during the the current
year without
quantification that would allow users to understand the impact of each
factor. Refer to
Item 303(b) of Regulation S-K and Section III.D of Release No. 33-6835
(501.04 of our
Codification of Financial Reporting Policies) for guidance.
August 14, 2024
Page 2
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 Abe Friedman at 202-551-8298 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services