Cornerstone OnDemand, Inc., Correspondence with SEC Division of Corporation Finance (2018)

Date issued: Oct. 08 2018

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TURBOFAC Commentary (460 words)

Notes:

*The version of the GL in force as of the time of the correspondence can be found at https://www.govinfo.gov/content/pkg/CFR-2020-title31-vol3/xml/CFR-2020-title31-vol3-part542.xml#seqnum542.516. Note that the below was drafted prior to the November, 2021 revisions to 541.516.

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1) The 2018 press release to which Cornerstone OnDemand (Cornerstone) refers can be found here. The press release explains that a “nonprofit organization” founded by Cornerstone had, “in partnership with Mercy Corps and the International Rescue Committee (IRC), [] announced the results of the first phase of its [USAID Office of Foreign Disaster Assistance]-funded program, Investing in Syrian Humanitarian Action (ISHA), which [had] provided online learning to more than 13,000 aid workers, allowing them to more effectively respond to humanitarian needs across Syria.”

The letter to the SEC explains that the “[Cornerstone OnDemand]...