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United States securities and exchange commission logo
October 13, 2022
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, 2021
Filed March 10,
2022
File No. 001-36397
Dear Gaofei Wang:
We have reviewed your September 22, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
August 26, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Risk Factors
Summary of Risk Factors, page 13
1. We note the proposed
revisions provided in response to prior comment 1, including a
statement that the
laws, regulations and the discretion of mainland China governmental
authorities discussed
in this annual report are expected to apply to mainland China entities
and businesses, rather
than entities or businesses in Hong Kong which operate under a
different set of laws
from mainland China. Please revise to disclose that the PRC
government has
significant authority to intervene or influence your Hong Kong operations
at any time.
Gaofei Wang
Weibo Corporation
October 13, 2022
Page 2
Item 5. Operating and Financial Review and Prospects
Results of Operations, page 117
2. We note from your response to prior comment 7 that for customers who
transact business
with the company through advertising agencies, the advertising agency
collects payment
from the advertiser, including payment for online advertising services
rendered by the
company and other professional services provided by the advertising
agency. Please tell
us what portion of the advertisers' payments are included in the
company's revenue. That
is, clarify whether you recognize the total payment collected by the
advertising agency or
only the portion related to the online advertising services. If you
recognize the total
payment collected by the advertising agency, tell us how you account for
the portion
related to services provided by the advertising agency as well as any
sales rebates
provided to the advertising agency. Also, tell us the amount of revenue
generated from
business transacted through distributors and third-party advertising
agencies for each
period presented. Lastly, revise your disclosures in Note 2 to your
consolidated financial
statements, as necessary.
3. You state that the total number of advertisers was 1.0 million in 2021
compared to 1.6
million in 2020. Please tell us, and revise to disclose, how you define
"advertisers." With
regard to business transacted through advertising agencies, specifically
clarify whether
you consider the advertising agency or the advertiser as your customer,
and describe to us
the agreements between you and the advertising agency and you and the
advertiser, if
any. In this regard, you disclose on page 77 that you enter into
agreements with
advertising agencies and that you may provide sales rebates to
advertising agencies. Also,
tell whether any advertising agency comprised more than 10% of your
revenue during
each period presented. If so, tell us the percentage of revenue generated
from each such
agency.
You may contact Joyce Sweeney, Senior Staff Accountant, at (202)
551-3449 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any
questions.
Sincerely,
FirstName LastNameGaofei Wang
Division of
Corporation Finance
Comapany NameWeibo Corporation
Office of Technology
October 13, 2022 Page 2
cc: Yuting Wu
FirstName LastName