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July 31, 2019
VIA EDGAR
United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attention: Division of Corporation Finance
Office of Telecommunications
Re: Teladoc Health, Inc.
Form 10-K for Fiscal Year Ended December 31, 2018
Filed February 27, 2019
File No. 001-37477
Dear Messrs. Shapiro and Cascarano:
Set forth below is the response of Teladoc Health, Inc. (the “Company”) to the comment contained in the letter dated July 23, 2019 from the staff (the “Staff”) of the Securities and Exchange Commission. For your convenience, the Staff’s comment is reproduced in bold type below and is followed by the Company’s response thereto.
Form 10-K for Year Ended December 31, 2018
Consolidated Statements of Operations
For the Years Ended December 31, 2018, 2017 and 2016, page F-4
1. We note you present gross profit on the face of your consolidated statements of operations. However, it is not clear whether you include depreciation and amortization in cost of revenue. Please note that the presentation of a figure for income before depreciation and amortization is not appropriate. Revise your presentation, as necessary, to comply with the guidance in Codification of Staff Accounting Bulletins (SAB) Topic 11B. Refer also to Item 302(a)(1) of Regulation S-K.
Response: In response to the Staff’s comment, in future filings, the Company will remove the “Gross profit” subtotal from its consolidated statements of operations.
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Kindly direct any questions you may have to the undersigned at (203) 987-6957. Any additional comments may be sent via facsimile to the undersigned at (203) 702-5243. Thank you.
| Very truly yours, |
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| /s/ Mala Murthy |
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| Mala Murthy |
| Chief Financial Officer |
| TELADOC HEALTH, INC. |
cc: Jason Gorevic of Teladoc Health, Inc.
Adam C. Vandervoort of Teladoc Health, Inc.
Brandon J. Bortner of Latham & Watkins LLP
Christopher J. Clark of Latham & Watkins LLP