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United States securities and exchange commission logo
June 9, 2021
Eido Gal
Chief Executive Officer
Riskified Ltd.
220 5th Avenue, 2nd Floor
New York, NY 10001
Re: Riskified Ltd.
Amendment No. 1 to
Draft Registration
Statement on Form F-1
Submitted May 26,
2021
CIK No. 0001851112
Dear Mr. Gal:
We have reviewed your amended draft registration statement 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 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 comments apply 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 these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 submitted
May 26, 2021
Prospectus Summary, page 8
1. We note your amended
disclosure in response to comment 1. We note your
statement "[w]e drive
higher sales and reduce fraud and other operating costs for our
merchants and strive to
provide superior consumer experiences." With respect to this
statement, please
disclose what you are using as a baseline comparison for higher sales,
reduced fraud, and
other operating costs. We also note your statement "[w]ithout
Riskified, merchants
attempt to solve these problems on their own using a variety of
legacy or in-house
solutions and manual processes." Please tell us whether you believe
that you have any
direct competitors or whether you believe that you are the only
Eido Gal
Riskified Ltd.
June 9, 2021
Page 2
ecommerce risk management platform currently available to merchants.
Strong expertise serving the enterprise market, page 16
2. We note your amended disclosure in response to comment 4. Please explain
the
significance of focusing on enterprise merchants generating over $75
million in online
sales per year, with a view to helping investors understand your
business. In this light, we
note the three reasons that you provide regarding your ability to
support enterprise
merchants, but there does not seem to be a clear correlation between
your three reasons
and the $75 million threshold.
3. Revenue Recognition
Disaggregation of Revenue, page F-22
3. We note your response to comment 15. Please disclose that you primarily
generate
revenues from the chargeback guarantee product and that revenues from
other products
are not material.
You may contact Keira Nakada at (202) 551-3659 or Doug Jones at (202)
551-3309 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Cara Wirth at (202) 551-7127 or Jacqueline Kaufman at (202) 551-3797
with any other
questions.
Sincerely,
FirstName LastNameEido Gal
Division of
Corporation Finance
Comapany NameRiskified Ltd.
Office of Trade &
Services
June 9, 2021 Page 2
cc: Marc D. Jaffe
FirstName LastName