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United States securities and exchange commission logo
May 16, 2023
Aglika Dotcheva
Chief Financial Officer
Riskified Ltd.
220 5th Avenue, 2nd Floor
New York, NY 10001
Re: Riskified Ltd.
Form 20-F for the
Fiscal Year Ended December 31, 2022
File No. 001-40692
Dear Aglika Dotcheva:
We have limited our review of your filing to the financial
statements and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 4. Information on the Company
Our Merchants, page 57
1. Please revise the
charts to make the legends and axis labels more easily readable.
Item 5. Operating and Financial Review and Prospects
A. Operating Results
Comparison of the Years Ended December 31, 2022 and 2021, page 73
2. You attribute part of
the growth in revenue to new merchants. Please discuss and quantify
the effect for each
factor identified.
3. Please expand your
discussion of cost of revenues to discuss the drivers related to increase
in net chargeback
expenses. You recorded net chargeback expenses of $103.2 million and
$85.5 million for the
years ended December 31, 2022 and 2021, respectively. However,
your provision for
chargebacks, net on your consolidated balance sheets were
Aglika Dotcheva
Riskified Ltd.
May 16, 2023
Page 2
$12.0 million and $12.0 million as of December 31, 2022 and 2021,
respectively. Please
explain how the chargeback expenses impact your gross margins and
discuss material
future trends that would be relevant to an investor.
Consolidated Financial Statements
General, page F-1
4. Please tell us how you considered the disclosures specified in Rule
12-09 of Regulation S-
X with regard to valuation and qualifying accounts. In this regard, we
note your
liability for guarantee obligations and your provision for
chargebacks. In the alternative,
information similar to that specified under ASC 460-10-50-8 would
provide a
comparable roll forward.
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-15
5. You state on page F-16 that access to your cloud-hosted software is
considered one
performance obligation in the context of the contract and accordingly
the transaction price
is allocated to this single performance obligation. However, you state
on page F-15 that
your fee is allocated between the consideration owed to you for your
fraud review service
and the consideration owed to you for issuing indemnification
guarantees which are
recorded at fair value. Please revise or advise as appropriate.
In closing, 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.
You may contact Nasreen Mohammed at 202-551-3773 or Lyn Shenk at
202-551-3380
with any questions.
FirstName LastNameAglika Dotcheva Sincerely,
Comapany NameRiskified Ltd.
Division of
Corporation Finance
May 16, 2023 Page 2 Office of Trade &
Services
FirstName LastName