Roblox Corporation has submitted a letter to the U.S. Securities and Exchange Commission (SEC) on April 23, 2024, in response to the SEC's comments regarding the company's financial disclosures. The SEC's concerns, dated April 12, 2024, pertained to Roblox's Form 10-K for the fiscal year ended December 31, 2023, and Form 8-K filed on February 7, 2024, which reported the company's fourth-quarter and full-year financial results for 2023. The SEC's comments focused on Roblox's use of Covenant Adjusted EBITDA, a non-GAAP financial measure, in its earnings releases and shareholder letters. The SEC advised that if the measure is material to understanding the company's financial condition or liquidity, it should be discussed only in the liquidity section of...Show More

Roblox Corporation has submitted a letter to the U.S. Securities and Exchange Commission (SEC) on April 23, 2024, in response to the SEC's comments regarding the company's financial disclosures. The SEC's concerns, dated April 12, 2024, pertained to Roblox's Form 10-K for the fiscal year ended December 31, 2023, and Form 8-K filed on February 7, 2024, which reported the company's fourth-quarter and full-year financial results for 2023. The SEC's comments focused on Roblox's use of Covenant Adjusted EBITDA, a non-GAAP financial measure, in its earnings releases and shareholder letters. The SEC advised that if the measure is material to understanding the company's financial condition or liquidity, it should be discussed only in the liquidity section of filed documents. Roblox acknowledged the SEC's comments and confirmed that it has limited the discussion of Covenant Adjusted EBITDA to the liquidity sections of its financial reports and earnings releases. The company emphasized the importance of Covenant Adjusted EBITDA to debtholders, investors, and management for assessing financial condition and liquidity. It also noted that the measure is tied to executive compensation, including the CEO's, and is a material term under the indenture governing its senior notes due 2030. Roblox proposed to continue disclosing Covenant Adjusted EBITDA in its liquidity sections to ensure full and fair disclosure and to avoid potential selective disclosure of material information.