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United States securities and exchange commission logo
May 25, 2021
Gleb Budman
Chief Executive Officer
Backblaze, Inc.
500 Ben Franklin Ct.
San Mateo, CA 94401
Re: Backblaze, Inc.
Amendment No. 1 to
Draft Registration
Statement on Form S-1
Submitted May 11,
2021
CIK No. 0001462056
Dear Mr. Budman:
We have reviewed your amended draft registration statement and
have the following
comment. In our comment, we may ask you to provide us with information
so we may better
understand your disclosure.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to the
comment and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Revenue Recognition, page F-10
1. You disclose that
revenues from subscription-based arrangements are recognized on a
straight-line basis
over the contractual term and fees from consumption-based
arrangements are
recognized as services are delivered based on the amount of daily
storage consumed.
Please tell us what consideration was given to disaggregating revenue
by these categories.
Refer to ASC 606-10-55-90 and 55-91.
Gleb Budman
FirstName
Backblaze, LastNameGleb Budman
Inc.
Comapany
May NameBackblaze, Inc.
25, 2021
May 25,
Page 2 2021 Page 2
FirstName LastName
You may contact Amanda Kim, Senior Staff Accountant, at 202-551-3241 or
Stephen
Krikorian, Accounting Branch Chief, at 202-551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Kathleen Krebs,
Special Counsel, at 202-551-3350 or Jan Woo, Legal Branch Chief, at
202-551-3453 with any
other questions.
Sincerely,
Division of Corporation
Finance
Office of Technology
cc: Bennett L. Yee, Esq.