TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo July 30, 2020 Edward McGowan Chief Financial Officer Akamai Technologies Inc 145 Broadway Cambridge, Massachusetts 02142 Re: Akamai Technologies Inc Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 28, 2020 File No. 0-27275 Dear Mr. McGowan: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2019 Financial Statements and Supplementary Data 2. Summary of Significant Accounting Policies Cost of Revenue, page 58 1. Please tell us the GAAP guidance you applied that did not result in the culmination of the earnings process in situations where certain ISPs provide you rack space and access to their bandwidth at a discount or no cost in return for use of your servers. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Tony Watson at (202) 551-3318 or Bill Thompson at (202) 551- 3344 with any questions. Edward McGowan Akamai Technologies Inc July 30, 2020 Page 2 FirstName LastNameEdward McGowan Sincerely, Comapany NameAkamai Technologies Inc Division of Corporation Finance July 30, 2020 Page 2 Office of Trade & Services FirstName LastName