September 4, 2019
Gaofei Wang
Chief Executive Officer
Weibo Corporation
8/F, QIHAO Plaza, No. 8 Xinyuan S. Road
Chaoyang District, Beijing 100027
People's Republic of China
Re: Weibo Corporation
Form 20-F for the Fiscal Year Ended December 31, 2018
Filed April 29, 2019
File No. 001-36397
Dear Mr. Wang:
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, 2018
Operating and Financial Review and Prospects
Results of Operations, page 89
1. On page 91 you disclose that the increased revenue from key accounts was
partly
attributable to an increasing number of key account customers allocating
more digital
advertising budget to social marketing. Please describe for us the
metrics used to monitor
monetization in managing your advertising business, such as your ability
to attract and
retain advertisers and increase advertisers' spending. In this regard, we
note
management's statements in your fourth quarter 2018 earnings call, which
attribute the
strong performance of the key accounts sector to growth in average
revenue for advertiser
spending and continued expansion of your customer base. Refer to Item 5.A
of Form 20-
F and Part III.B of SEC Release 33-8350.
Gaofei Wang
FirstName LastNameGaofei Wang
Weibo Corporation
Comapany 4, 2019
September NameWeibo Corporation
Page 2
September 4, 2019 Page 2
FirstName LastName
2. We note the significant increase in revenue sharing cost in 2018,
which you state is
primarily related to your advertisement production and live streaming
business. Please
separately quantify the amount or percentage of revenue attributable
to revenue sharing
arrangements, if material. To the extent there are any trends in the
proportion of
revenue earned through such arrangements and/or the average revenue
share ratios,
include a discussion of such trends and the impact on your results of
operations. In your
response, please tell us the amount of revenue from revenue sharing
arrangements
presented on a gross basis and the related revenue sharing costs for
each period presented,
separately identifying advertising and marketing services and
value-added services. For
arrangements where revenue is presented on a net basis, tell us the
amount of gross
revenue and the revenue share that was netted against such revenue for
each period
presented. Refer to Item 5.A and 5.D of Form 20-F and Part III.B of
SEC Release 33-
8350.
Consolidated Financial Statements
Note 2. Significant Accounting Policies
Revenue recognition, page F-14
3. Please describe for us the nature and terms of your revenue sharing
arrangements related
to advertising and marketing services. Tell us the specified good or
service being
provided to the customer and describe your consideration of the
guidance in ASC 606-10-
55-36 through 55-40. If revenues recognized from revenue sharing
arrangements are
significant, disclose your related policy as well as the significant
judgments and
assumptions made in determining gross or net presentation of such
revenues. Refer to
ASC 606-10-50-1.
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 David Edgar, Staff Accountant, at (202) 551-3459 or
Joyce Sweeney,
Staff Accountant, at (202) 551-3449 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Information Technologies
and Services