United States securities and exchange commission logo
April 8, 2021
Jill Woodworth
Chief Financial Officer
Peloton Interactive, Inc.
125 West 25th Street, 11th Floor
New York, New York, 10001
Re: Peloton
Interactive, Inc.
Form 10-K for the
fiscal year ended June 30, 2020
Response dated
March 30, 2021
File No. 001-39058
Dear Ms. Woodworth:
We have reviewed your March 30, 2021 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to our comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to our comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
March 17, 2021 letter.
Form 10-K for the fiscal year ended June 30, 2020
Response dated March 30, 2021, page 1
1. We note your response
to comment one. Please clearly explain to us how you determine
which copyright and
patent litigation matters are considered to be outside the-ordinary-
course and therefore
excluded from your non-GAAP measures. We note from
disclosure in other
parts of your annual report, that your success depends in large part on
your proprietary
technology and your patents, trade secrets, trademarks, and other
intellectual property
rights and that you spend significant resources to monitor and protect
these rights. As such,
it would be reasonable that related costs would be normal, recurring
operating expenses.
Please explain and tell us the other types of matters that you consider
to be extraordinary in
nature.
Jill Woodworth
Peloton Interactive, Inc.
April 8, 2021
Page 2
You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or
Melissa
Gilmore, Staff Accountant, at (202) 551-3777 if you have any questions.
FirstName LastNameJill Woodworth Sincerely,
Comapany NamePeloton Interactive, Inc.
Division of Corporation
Finance
April 8, 2021 Page 2 Office of Manufacturing
FirstName LastName