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United States securities and exchange commission logo
June 3, 2024
Bart Volkmer
General Counsel
DROPBOX, INC.
1800 Owens St.
San Francisco , California 94158
Re: DROPBOX, INC.
Form 8-K filed May
1, 2024
File No. 001-38434
Dear Bart Volkmer:
We have reviewed your
filing and have the following comment.
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
the 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.
Form 8-K filed May 1, 2024
General
1. We note the statement
that you experienced a cybersecurity incident in your Form 8-K
filed on May 1, 2024.
Please advise us as to why you determined to file under Item 1.05 of
Form 8-K given your
statements that the incident has not had a material impact on your
business operations,
you do not believe it is likely to have a material impact on your
overall business
operations and you have not determined whether the incident is
reasonably likely to
materially impact financial condition or results of operations.
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.
Please contact Geoffrey Kruczek at 202-551-3641 or Suzanne Hayes
at 202-551-3675
with any other questions.
Bart Volkmer
DROPBOX, INC.
June 3, 2024
Page 2
Sincerely,
FirstName LastNameBart Volkmer
Division of Corporation Finance
Comapany NameDROPBOX, INC.
Office of Manufacturing
June 3, 2024 Page 2
cc: Lisa Stimmell
FirstName LastName