February 5, 2021
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
Attention: Linda Cvrkel and Rufus Decker
|
|
Re: |
Revolve Group, Inc. |
Ladies and Gentlemen:
Revolve Group, Inc. (the “Company”) submits this letter in response to an oral comment from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received on February 2, 2021, relating to the Company’s Form 10-K for the year ended December 31, 2019 (File No. 001-38927) originally filed with the Commission on February 26, 2020.
In response to the Staff’s comment, the Company hereby undertakes to disclose its net sales for each category of similar products as required under ASC 280-10-50-40, on a prospective basis beginning with its Annual Report on Form 10-K for the year ended December 31, 2020 (the “2020 Form 10-K”).
The Company respectfully advises the Staff that it intends to include the following disclosure in the 2020 Form 10-K (with the tables populated):
Securities and Exchange Commission
February 5, 2021
Page 2
The following tables summarize net sales and percentage of net sales by product category for the years ended December 31, 2020, 2019 and 2018 (dollars in thousands):
|
|
|
Years Ended December 31, |
|
|||||||||
|
|
|
2020 |
|
|
2019 |
|
|
2018 |
|
|||
|
Net sales |
|
|
|
|
|
|
|
|
|
|
|
|
|
Fashion apparel |
|
$ |
|
|
|
$ |
|
|
|
$ |
|
|
|
Dresses |
|
|
|
|
|
|
|
|
|
|
|
|
|
Handbags, shoes and accessories |
|
|
|
|
|
|
|
|
|
|
|
|
|
Beauty |
|
|
|
|
|
|
|
|
|
|
|
|
|
Other(1) |
|
|
|
|
|
|
|
|
|
|
|
|
|
Total net sales |
|
$ |
|
|
|
$ |
|
|
|
$ |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
As a percentage of net sales |
|
|
|
|
|
|
|
|
|
|
|
|
|
Fashion apparel |
|
|
|
% |
|
|
|
% |
|
|
|
% |
|
Dresses |
|
|
|
% |
|
|
|
% |
|
|
|
% |
|
Handbags, shoes and accessories |
|
|
|
% |
|
|
|
% |
|
|
|
% |
|
Beauty |
|
|
|
% |
|
|
|
% |
|
|
|
% |
|
Other (1) |
|
|
|
% |
|
|
|
% |
|
|
|
% |
|
Total net sales |
|
|
100 |
% |
|
|
100 |
% |
|
|
100 |
% |
(1) Includes deferred revenue, shipping revenue and other revenue.
* * * * *
Please direct your questions or comments to me at (562) 677-9480.
|
Very truly yours, |
|
/s/ Jesse Timmermans |
|
Jesse Timmermans |
|
cc: |
Jodi Lumsdaine Chapin, Esq., Revolve Group, Inc. |
Michael Nordtvedt, Wilson Sonsini Goodrich & Rosati, Professional Corporation
Jeffrey Rawlins, KPMG LLP