Viant Technology Inc. (DSP)

Company response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that, consistent with the requirements of Item 303 of Regulation S-K, management considers and discloses matters in its periodic reports that are necessary to an understanding of the Company’s financial condition, changes in financial condition and results of operations, including factors that have had, or are reasonably likely to have, a material impact on the Company’s results of operations, financial condition, or liquidity. Management has considered whether to provide a quantified discussion of total advertiser spend and concluded that such quantified discussion would not provide meaningful insight into the… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that the percentage increase in the number of spend customers generating over $1 million in contribution ex-TAC and the contribution ex-TAC across the Company’s top 100 customers are not key performance measures used by management to manage the business within the meaning of Item 303 of Regulation S-K and Commission Release No. 33-10751. The Company’s key performance measures are disclosed in “ Management’s Discussion and Analysis of Financial Condition and Results of Operations—Key Operating and Financial Performance Measures ” sections of its periodic reports. These measures are used by management to manage… response letter →

Company response: to comment 3 in your January 24, 2022 letter. Response : The Company respectfully acknowledges the Staff’s comment and advises the Staff that quantifying revenue growth attributable to new versus existing customers would not provide meaningful information to investors, and attempting to do so could be potentially confusing. As disclosed in “ Management’s Discussion and Analysis of Financial Condition and Results of Operations—Factors Affecting Our Performance ” in the Company’s Form 10-K for the year ended December 31, 2023, as the business has scaled, management’s focus has shifted to customers with the ability to expand their spend on the Company’s platform, regardless of whether such… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that, in preparing its periodic disclosures, management considers and discloses matters that have had, or are reasonably likely to have, a material impact on the Company’s results of operations, consistent with Item 303(a) of Regulation S-K. Management has considered whether to provide quantified disclosure of changes in digital advertising spend by channel, including CTV, and concluded that such quantified disclosure would not provide meaningful insight into the Company’s operating performance. The allocation of advertising spend among digital channels reflects customer-directed purchasing decisions, rather… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and notes that this disclosure was inadvertently omitted from its Form 10-K due to a typographical error. On December 10, 2025, the Company filed Amendment No. 1 to Annual Report on Form 10-K/A to disclose management’s assessment regarding the effectiveness of its internal control over financial reporting as of December 31, 2024. response letter →