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United States securities and exchange commission logo
February 5, 2021
Amir Schlachet
Chief Executive Officer
Global-E Online Ltd.
25 Basel Street
Petah Tikva 4951038, Israel
Re: Global-E Online
Ltd.
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted January
22, 2021
CIK No. 0001835963
Dear Mr. Schlachet:
We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments. References to prior comments are to those in our letter dated
January 13, 2021.
Amendment No. 1 to Draft Registration Statement on Form F-1
Risk Factors
"Legal, political, and economic uncertainty surrounding the exit of the
United Kingdom from the
EU..." , page 34
1. Please update this risk
factor as the transition period during which EU rights and
obligations still
applied to the UK expired on December 31, 2020.
Results of Operations
Year ended December 31, 2019 compared to year ended December 31, 2018 ,
page 77
2. We note you now
separately present revenue and cost of revenue by service fees and
fulfillment in response
to prior comment 6. However, it does not appear that you
Amir Schlachet
Global-E Online Ltd.
February 5, 2021
Page 2
separately analyze revenue and cost of revenue between service fees and
fulfillment
revenue. Please expand your disclosures accordingly. Refer to Section
III.B of SEC
Release No. 33-8350.
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-10
3. We have reviewed your response to prior comment 14. Please include more
of your
response in your disclosure. In this regard, revise your disclosure to
indicate that you do
provide your platform service solution on a standalone basis. Please
disclose the amount
of revenue recognized from the sale of platform service solutions without
fulfillment
services.
4. We have reviewed your response to prior comment 15. To help the staff
understand the
conclusion reached by the Company, we have the following comments. Please
clarify
whether you have a present right for payment upon the products arrival at
your hub. We
refer you to ASC 606-10-25-30. Explain how you determined that the
service obligation
is separately identifiable from the fulfillment obligation. Refer to ASC
606-10-25-19(b)
and 25-21. In this regard, it seems that your customers are utilizing
your services to
consummate the sale and deliver the product to the shopper. Tell us
whether risk of
satisfying that outcome binds the two obligations into one combined
promised service
(i.e., the delivery of desired product to the shopper).
You may contact Ryan Rohn, Staff Accountant, at (202) 551-3739 or
Stephen Krikorian,
Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the
financial statements and related matters. Please contact Matthew Crispino,
Staff Attorney, at
(202) 551-3456 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
FirstName LastNameAmir Schlachet
Division of
Corporation Finance
Comapany NameGlobal-E Online Ltd.
Office of
Technology
February 5, 2021 Page 2
cc: Josh Kiernan
FirstName LastName