Via EDGAR
July 9, 2019
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Information Technologies and Services
100 F Street N.E.
Washington, D.C. 20549
| Attn: | David Edgar, Staff Accountant |
Melissa Kindelan, Staff Accountant
| Re: | salesforce.com, inc. |
Form10-K for the Fiscal Year Ended January 31, 2019
Filed March 8, 2019
Form8-K furnished June 4, 2019
FileNo. 001-32224
Ladies and Gentlemen:
We are responding to the comment contained in the letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed to Mark Hawkins, Chief Financial Officer of salesforce.com, inc. (the “Company”), dated June 14, 2019 (the “Comment Letter”) related to the above referenced filings. For your convenience, we have repeated the comment contained in the Comment Letter before our response below.
Form8-K furnished June 4, 2019
Exhibit 99.1
GAAP Results Reconciled tonon-GAAP Results, page 12
1. We note that yournon-GAAP measures include an adjustment for “Amortization of purchased intangibles.” Excluding amortization of purchased intangible assets may result innon-GAAP measures that are based on individually tailored accounting principles. Please tell us how you considered Question 100.04 of theNon-GAAP C&DIs and why you believe these measures are useful to investors.
Based on our discussion on July 3, 2019 with members of the Staff, we understand that the Staff has determined not to pursue this comment at this time. We further understand that the Staff continues to believe that excluding amortization of purchased intangible assets may result in non-GAAP measures that are based on individually tailored accounting principles.
As discussed with the Staff, going forward we will include the following additional language in our discussion regarding our adjustment for amortization of purchased intangibles:
“Although we exclude the amortization of purchased intangibles from these non-GAAP measures, management believes that it is important for investors to understand that such intangible assets were recorded as part of purchase accounting and contribute to revenue generation.”
If you have any further comments or questions, please direct any such requests to Stewart McDowell of Gibson, Dunn & Crutcher LLP at (415)393-8322 or Joe Allanson of salesforce.com, inc. at (415)901-7000.
Very truly yours,
salesforce.com, inc.
/s/ Mark J. Hawkins |
Mark J. Hawkins
President and Chief Financial Officer
/s/ Joe Allanson |
Joe Allanson
Executive Vice President, Chief Accounting Officer and Corporate Controller
| cc: | Marc Benioff, Chairman of the Board of Directors andco-Chief Executive Officer |
Keith Block,Co-Chief Executive Officer
Amy Weaver, President, Legal and Corporate Affairs, General Counsel and Secretary
Sarah Dods, Executive Vice President, Corporate Counsel
Stewart McDowell, Esq., Gibson, Dunn & Crutcher LLP
