650 Town Center Drive, 20th Floor
Costa Mesa, California 92626-1925
Tel: +1.714.540.1235 Fax: +1.714.755.8290
|FIRM / AFFILIATE OFFICES|
December 18, 2020
VIA EDGAR AND FEDEX DELIVERY
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Matthew Crispino, Jan Woo
Playtika Holding Corp.
Amendment No. 1 to Draft Registration Statement on Form S-1
Confidentially submitted on November 20, 2020
CIK No. 0001828016
Ladies and Gentlemen:
On behalf of Playtika Holding Corp., a Delaware corporation (the Company), we are transmitting this letter in response to comments received from the staff (the Staff) of the Securities and Exchange Commission contained in its letter dated December 8, 2020, relating to the above referenced Amendment No. 1 to Draft Registration Statement on Form S-1, which was confidentially submitted on November 20, 2020 (the Draft Submission). We are submitting this letter via EDGAR and have publicly filed a revised Registration Statement on Form S-1 (the Registration Statement). For the Staffs convenience, we are also sending, by courier, copies of this letter as well as both a clean copy of the Registration Statement and a copy marked to show all changes from the Draft Submission.
For ease of review, we have set forth below, in bold type, each of the numbered comments in the Staffs letter, followed by the Companys responses thereto. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Registration Statement and all references to page numbers in such responses are to page numbers in Registration Statement.
December 18, 2020
Consolidated Financial Statements
Note 1. Organization and Summary of Significant Accounting Policies
Revenue recognition, page F-12
We note your response to prior comment 10. Please revise your disclosure to state, as you do in your response, that you do not know the total price paid by the customer to the service provider.
Response: The Company respectfully acknowledges the Staffs comment and has revised the disclosure on pages 95 and F-14.
* * *
We hope the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (714) 755-8197 with any questions or comments regarding this correspondence.
|Very truly yours,|
Michael Treska, Esq.
of LATHAM & WATKINS LLP
Craig Abrahams, President and Chief Financial Officer, Playtika Holding Corp.
Michael Cohen, Executive Vice President, General Counsel and Secretary, Playtika Holding Corp.
Charles K. Ruck, Esq., Latham & Watkins LLP
Benjamin A. Potter, Esq., Latham & Watkins LLP
Alan F. Denenberg, Esq., Davis Polk & Wardwell LLP