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United States securities and exchange commission logo
December 15, 2023
Dennis Story
Chief Financial Officer
Manhattan Associates, Inc.
2300 Windy Ridge Parkway, Tenth Floor
Atlanta, Georgia 30339
Re: Manhattan
Associates, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2022
Response dated
December 12, 2023
File No. 000-23999
Dear Dennis Story :
We have reviewed your December 12, 2023 response to our comment
letter and have the
following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our November 30,
2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations
Revenue, page 28
1. We note your response
to prior comment 2 and acknowledge the disclosure on page 24.
While that disclosure
indicates the mix of new to existing customers for cloud
subscriptions and
software license for sales in 2022, it is not clear what comprises the year
over year growth in
cloud subscription revenue. Therefore, as previously requested, please
tell us and revise to
disclose the amount or percentage of the increase in cloud
subscription revenue
attributable to new versus existing customers including those that are
migrating from
on-premise offerings to cloud offerings, in order to provide better context
to your results of
operations discussion.
Dennis Story
FirstName
Manhattan LastNameDennis
Associates, Inc. Story
Comapany15,
December NameManhattan
2023 Associates, Inc.
December
Page 2 15, 2023 Page 2
FirstName LastName
2. You indicate in your response to prior comment 2 that you will
disclose in future filings
the percentage of professional services revenue that relates to cloud
subscriptions, which
was approximately 25% in 2020 and over 50% in 2022. Please tell us and
revise to
disclose the actual percentages for fiscal 2021 and 2022, and explain
the types of
professional services that comprise the remaining amounts. Further, as
previously
requested, in order to better explain the year over year growth in
service revenue, tell us
and revise to disclose the amount or percentage of the increase
attributable to new versus
existing customers.
Please contact Chen Chen at 202-551-7351 or Melissa Kindelan at
202-551-3564 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Linda Pinne