Essay Case 1

Submitted By reerkoshin
Words: 405
Pages: 2

(Due 10/26/2014 10:00PM)

Case Requirements:
Form a group of no more than 4 students.
Go to the SEC website ( and locate Groupon’s initial registration statement (S-1) dated on 06/02/2011, the SEC’s comment letter dated on 06/30/2011, Groupon’s response on 07/14/2011, and Groupon’s revised registration statement (S-1/A) on 11/01/2011.
Read relevant materials from the SEC’s website and the FASB Accounting Standard Codification system. Answer the following 6 questions.

Peer Evaluation:
After the case due date, please email me the names of your group members (other than yourself) and evaluate each group member (other than yourself) on a scale of 0 (no effort and contribution to this project) to 10 (great effort and contribution to this project). Please give specific reasons if your evaluation is less than 6.

Due time: October 26, 2014 at 10:00 PM

Question 1: How did Groupon define the non-GAAP financial measure (Adjusted CSOI) in its registration statement? What was the SEC’s comment on this non-GAAP measure? How did Groupon defend its position in the subsequent correspondence? Please answer the above questions in your own words. If you choose to cite a source document, please clearly identify your source documents and use quotation marks around the quoted materials.

Question 2: Find the final rule for Regulation-G from the SEC’s website. How does Regulation-G define a “non-GAAP financial measure”? What kind of non-recurring items does Regulation-G prohibit a company from excluding when adjusting for non-GAAP financial measure? You can directly copy-paste from the final rule to answer this question.

Question 3: How should we account for marketing