KPIs, Metrics & Earnings Calls

Company response: The Company respectfully advises the Staff that, upon inception of the 2023 Gilead License Agreement, it identified three performance obligations. The agreement also provided Gilead with an option to purchase drug supply of GS-0321. The Company concluded that this option did not provide a material right and therefore did not represent a separate performance obligation. During the first half of 2026, Gilead exercised its option to purchase additional goods and services related to the supply of GS-0321. The Company undertakes to update its disclosure in future filings with the Commission to reflect the exercise of this option. The Company further advises the Staff that revenue associated with… response letter →

Company response: to the Staff’s request, the Company proposes to expand its discussion of revenue in Management’s Discussion and Analysis of Financial Condition and Results of Operations (“ MD&A ”) to include additional quantitative and qualitative information, as shown in the following proposed disclosure, regarding key drivers of revenue growth in the relevant period. Below is an example of such expanded disclosure using 2025 figures. “Revenue for the year ended December 31, 2025 increased by $902.3 million, or 69%, compared to the prior year. The growth in revenue was primarily due to an increase in advertising revenue of $877.0 million, or 74%, as compared to the prior year driven primarily by an… response letter →

Company response: to the Staff’s request, the Company proposes to expand its disclosure in the income tax footnote of the consolidated financial statements and in MD&A in its Q1 2026 Form 10-Q (and in future filings as appropriate) as follows: United States Securities and Exchange Commission Division of Corporation Finance “Given our recent history of generating net income in the United States, we believe that there is a reasonable possibility that sufficient positive evidence may become available within the next 12 months to allow us to release a significant portion of the federal valuation allowance. The reversal would result in a significant income tax benefit in the period when we release it. However,… response letter →

Company response: We acknowledge the Staff’s comment, and confirm that, in future filings, the Company will quantify all factors that we believe materially impact changes in financial statement line items and are reasonably practicable to quantify. We also confirm that disclosures based on that standard will be provided for each significant income statement line item, as outlined in the example disclosure below, as well as for the segment discussion. In certain instances, the Company refers to factors that are not reasonably practicable to quantify. In some cases, but not all, multiple interrelated factors—such as pricing, volume, and mix—cannot be response letter →

Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that it will revise future filings, beginning with its next Form 10-Q, to the extent practicable, to quantify the impact of each material factor contributing to material changes in its results of operations, rather than describing such factors qualitatively only. In future filings, when multiple material factors contribute to a change in a financial statement line item, the Company will quantify the impact of each material driver, including by product line, geographic market, or other relevant category, as appropriate, to provide investors with a more transparent understanding of the underlying reasons for the… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that future annual reports on Form 20-F, including our Annual Report on Form 20-F for the fiscal year ending September 30, 2026, will present managed service renewal rates and 12-month backlog as key performance indicators (until and unless we conclude in the future that such metrics are no longer key performance indicators for our business and cease disclosing them). For the Staff’s reference, here is a markup of the relevant language we expect to include in our future filings (with this language reflecting what would have been included in the Annual Report): Revenue from managed services arrangements is a significant… response letter →

Company response: The Company acknowledges the Staff’s comment and the guidance in Item 303(b) of Regulation S-K. In preparing the MD&A, the Company identified multiple factors contributing to period-to-period changes in net revenue and other income statement line items, including changes in volume, product and customer mix, pricing, and other factors. In response to the Staff’s comment, the Company will revise its future filings to quantify, where possible, the impact of each material contributing factor, including any offsetting factors, in dollars and/or percentages, and to expand its discussion of the underlying reasons driving these changes. The Company will apply this enhanced level of quantification… response letter →

Company response: The Company respectfully acknowledges the Staff's comment. In future filings, beginning with the Quarterly Report on Form 10-Q for the fiscal quarter ending March 31, 2026, we will revise the discussion of financial condition under Item 303(b) of Regulation S-K to provide disclosure of material period-over-period changes in our loan balances by product type, including quantification and discussion of the factors driving material changes. Results of Operations Comparison of the Years Ended June 30, 2025 and 2024, page 68 response letter →

Company response: The Company acknowledges the Staff’s comment and hereby confirms to the Staff that it will include in future periodic reports a qualitative and quantitative discussion of orders and backlog similar in scope to the information included in the Company’s Q4 Fiscal Year 2025 earnings presentations. Johnson Controls, Inc. 5757 N Green Bay Ave, Milwaukee, WI 53209 Segment Analysis, page 35 response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that beginning with its Annual Report on Form 10-K for the fiscal year ending March 31, 2026 (the “2026 10-K”) it will provide (i) additional disclosure defining the use of its clinical workflow tools by unique active providers on a quarterly basis and (ii) comparable data on the metric for the prior period. 1 The following is an example of how the Company expects to provide this additional disclosure, which will be included in the Key Business and Financial Metrics section of Management’s Discussion and Analysis of Financial Condition and Results of Operations beginning with the 2026 10-K. “Quarterly Unique Active… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and refers the Staff to its response to comment 1 above for future disclosures regarding the number of quarterly unique active providers using its workflow tools. The Company notes that user engagement metrics have been referenced on earnings calls periodically, primarily in response to analyst and investor questions from prior periods, to provide supplemental context regarding platform activity. These references were not intended to convey that management relies on such metrics to evaluate financial condition or allocate resources. The majority of the engagement metrics identified in the Staff's comment were referenced… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that beginning with its 2026 10-K it will provide additional clarifying disclosure regarding the U.S. physicians that are included in the percentage of U.S. physician calculations. The following is an example of how the Company expects to provide this additional disclosure, which will be included in the Business section of the 2026 10-K. “We are the leading digital platform for U.S. medical professionals, with over [●] registered members 2 as of March 31, 2026. Our registered members represent more than [●]% of U.S. physicians, spanning all 50 states and every medical specialty, along with over [●]% of U.S. nurse… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has considered the disclosure requirements of Item 303(b)(2) of Regulation S-K, however, the Company does not track or manage revenue at the individual module level, and its financial systems do not have the capability to identify or allocate revenue by module. Although the Company tracks module usage for operational purposes, and available data indicates that the newsfeed module was the most widely used product during the period, management does not use module-level usage data to assess revenue performance. As noted in the Company’s response to comment 2 above, the Company does not believe user… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has considered the disclosure requirements of Item 303(c) of Regulation S-K, however, the discussion regarding policy headwinds in the February 5, 2026 earnings call did not result in a material change to our liquidity and results from operations for the three and nine months ended December 31, 2025, and was only intended to provide additional color to analysts and investors on industry dynamics due to uncertainty surrounding the Most Favored Nation (“MFN”) pricing negotiations between certain pharmaceutical companies and the federal government. As of February 5, 2026, sixteen out of the seventeen… response letter →

Company response: , please explain how you determined that these were not normal, recurring, cash operating expenses of your business. Refer to Question 100.01 of the non-GAAP C&DIs. Response : The Company respectfully acknowledges the Staff’s comment and has considered the guidance set forth in Question 100.01 of the Compliance and Disclosure Interpretations related to non-GAAP measures (“ C&DI 100.01 ”). The Company believes that making adjustments to exclude acquisition related compensation and benefits is appropriate and consistent with the guidance provided in C&DI 100.01 and further believes that such adjustments enhance the clarity and usefulness of the Company’s non-GAAP financial measures for its… response letter →

Company response: In response to the Staff’s comment, while the Company acknowledges that the OCC has imposed individual minimum capital requirements on its indirect subsidiary, First Federal of Kentucky (the “Bank”), the Bank has not been designated as “less than well capitalized” and has maintained capital levels in excess of the noted individual minimum capital requirements. As such there have been no restrictions or waiver requirements imposed on the Bank for rolling brokered deposits or other types of wholesale deposits. Nevertheless, pursuant to the Staff’s comment, to the extent that these items remain in place, the Company will revise its future filings in all appropriate circumstances to clarify… response letter →

Company response: to this comment, commencing with our FY 2026 Form 10-K, we will move the sections entitled “Adjusted EBITDA” and “Non-GAAP net income,” which include a discussion of non-GAAP financial measures, from their current location to a new section to be captioned “Non-GAAP financial measures” that follows the “Results of operations” section, which contains a discussion of our GAAP results, so that our discussion and analysis of our GAAP measures have equal or greater prominence than our non-GAAP discussion. Our existing section titled “Key financial and operating metrics” will accordingly be renamed “Key operating metrics” to reflect the removal of these sections, as the sections “Adjusted EBITDA”… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment. In future filings, beginning with the Company’s Form 10-K for the year ending February 28, 2026, we will expand our disclosures in Management’s Discussion and Analysis of Financial Condition and Results of Operations to include information substantially similar to the following (example based on amounts from the 10-Q for the fiscal quarter ended November 30, 2025): Sales for the AZZ Metal Coatings segment increased $26.4 million, or 15.7%, for the current quarter, compared to the prior year quarter. The increase was primarily due to $30.0 million resulting from a higher volume of steel processed, primarily due to increases in the… response letter →

Company response: to prior comment 6, including your statements that you do not present GAAP gross profit or GAAP gross margin in your Consolidated Statements of Operations because certain costs related to contract revenues are expensed as incurred and included in research and development expenses and it is not practicable to allocate such expenses to cost of sales. We also note you now believe the adjusted non-GAAP gross profit and adjusted non-GAAP gross margin measures you present should be categorized as Key Performance Metrics (KPMs) because: (1) they are consistent with how you reflect your business in internal financial statements; (2) they are consistent with how your leadership and Chief Executive… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in future filings the Company will remove the line item for unallocated corporate expenses and the total for the amounts of other segment items. In addition, in future filings, the Company will revise and expand its disclosure in Note 20 to state that the chief operating decision maker reviews expenses on a consolidated basis and that no segment level expense information is regularly provided to the chief operating decision maker. The Company will also relocate from Note 1 to Note 20 its existing disclosure that describes how the chief operating decision maker uses segment Adjusted EBITDA to assess segment… 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 acknowledges the Staff’s comment, and in future filings, beginning with our Form 10-Q for the quarter ended September 30, 2025, we will expand disclosures to provide additional quantitative information related to material factors contributing to period-over-period changes in our operating cash flows. In future filings, we intend to expand our disclosures to be similar to the example provided in the below revised disclosure excerpts from our Form 10-Q for the quarter ended June 30, 2025, within the Analysis of Cash Flow section of Management’s Discussion and Analysis of Financial Condition and Results of Operations, addressing the request for quantification of previously… response letter →