August 31, 2017
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549-3720
| Re: | Workday, Inc. |
Form 10-K for the year ended January 31, 2017
Filed March 20, 2017
Form 10-Q for the quarter ended April 30, 2017
Filed June 2, 2017
Ladies and Gentlemen:
On behalf of Workday, Inc. (“Workday”), set forth below is Workday’s response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the letter dated August 25, 2017. For ease of reference, the numbered paragraphs below correspond to the numbered comments in that letter; the Staff’s comments are presented in bold italics.
Form 10-Q for the quarter ended April 30, 2017
Notes to Condensed Consolidated Financial Statements
Note 2. Accounting Standards and Significant Accounting Policies
Revenue Recognition, page 10
| 1. | We note your response to prior comment 2. Please revise to disclose the method by which you amortize the initial commission costs over the five-year period of benefit. Please also disclose the method and period of time over which you amortize commission costs related to subsequent contract renewals. Refer to ASC 340-40-50-2. |
Workday advises the Staff that in response to the Staff’s comment it has updated its disclosure of use of estimates, critical accounting policies and deferred commissions in the Notes to Condensed Consolidated Financial Statements included on pages 9, 10, 14 and in the Management’s Discussion and Analysis of Financial Condition and Results of Operations on pages 30, 41 and 42 in in its Form 10-Q for the quarter ended July 31, 2017 filed on August 31, 2017.
6230 Stoneridge Mall Road, Pleasanton CA 94588 United States / main +1.925.951.9000 fax +1.925-951.9001 www.workday.com
Securities and Exchange Commission
August 31, 2017
Page 2
If you have any further questions, please feel free to contact the undersigned or Jeffrey Vetter of Fenwick & West LLP at (650) 335-7631.
| Sincerely, |
| Workday, Inc. |
| /s/ Robynne D. Sisco |
| Robynne D. Sisco |
| Chief Financial Officer |
| Cc: | Aneel Bhusri, Chief Executive Officer |
Trish Coughlin, Corporate Controller
James P. Shaughnessy, Esq., Senior Vice President, General Counsel and Secretary
Melanie D. Vinson, Esq., Deputy General Counsel, Corporate
Workday, Inc.
Gordon K. Davidson, Esq.
Jeffery R. Vetter, Esq.
Fenwick & West LLP
Dave Cabral
Ernst & Young LLP