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United States securities and exchange commission logo
August 4, 2023
Aidan Viggiano
Chief Financial Officer
Twilio Inc.
101 Spear Street, Fifth Floor
San Francisco, California 94105
Re: Twilio Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Response dated July
25, 2023
File No. 001-37806
Dear Aidan Viggiano:
We have reviewed your July 25, 2023 response to our oral comment
issued on July 12,
2023 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 10-K for the Fiscal Year Ended December 31, 2021
General
1. You appear to present
Non-GAAP gross profit as the measure of profit or loss for each
reportable segment in
the proposed disclosures in your letter dated July 25, 2023. Please
tell us what measures
of profit or loss at the segment level are provided to the CODM, the
frequency such measures
are provided to the CODM, and how they are used by the
CODM. Please address
all measures of segment profit or loss provided to the CODM,
including those
provided outside of the standard reporting package, such as during the
budgeting process,
meetings, or other means. If the CODM receives but does not use a
measure of segment
profit or loss, please tell us why.
2. If the CODM uses more
than one measure of segment profit or loss in assessing segment
performance and
deciding how to allocate resources, please tell us how you determined
which measure was
required to be disclosed. See ASC 280-10-50-28.
Aidan Viggiano
Twilio Inc.
August 4, 2023
Page 2
3. In the proposed disclosures in your letter dated July 25, 2023, you
reconcile your segment
measure of profit to gross profit. Please revise to reconcile your
segment measure of
profit to consolidated income before taxes and discontinued operations in
accordance with
ASC 280-10-50-32(f).
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371
or Robert
Littlepage, Accounting Branch Chief at 202-551-3361 if you have any questions.
Sincerely,
FirstName LastNameAidan Viggiano
Division of
Corporation Finance
Comapany NameTwilio Inc.
Office of Technology
August 4, 2023 Page 2
cc: Rezwan Pavri
FirstName LastName