PEverpure

We note you use Subscription Annual Recurring Revenue (ARR) as a key business metric to evaluate the performance of subscription services. Please expand your disclosure to address the following and advise us. • Clarify what "on-demand" revenue is and how it differs from annualized contract value from subscription agreements.

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• Clarify how ARR reflects new and existing customers and any actual or anticipated reductions of revenue due to contract non-renewals or cancellations, and discuss any limitations present as a result. • Disclose the renewal rates for subscription arrangements for each period presented to support your assumptions. • Describe how ARR differs from GAAP revenue and specifically address any adjustments made in accordance with ASC 606. 1. • Disclose whether ARR is indicative of future revenue and if not, how it may differ.

We respectfully acknowledge the Staff’s comment, and, in response to the comment, will expand our disclosure of Subscription Annual Recurring Revenue (“ARR”) and add disclosure of Subscription Net Dollar Retention to address the items raised, as set forth in our proposed responsive disclosures below.

On-demand revenue represents billings during a quarter for consumption by customers of our subscription services above a minimum usage commitment amount.

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The annualized value of on-demand revenue is calculated by multiplying such billings during the quarter by four.

In contrast, annualized contract value from subscription amounts represents the annualized recurring value of all active, non-cancelable subscription contracts with subscription terms of any length at the end of a quarter. The annualized contract value is calculated by dividing the total committed contract value of each contract by the number of days in the subscription term and then multiplying by 365 days.

Clarify how ARR reflects new and existing customers and any actual or anticipated reductions of revenue due to contract non-renewals or cancellations, and discuss any limitations present as a result.

The Company’s ARR calculation at the end of a quarter includes all customers, both existing customers at the beginning of the quarter as well as new customers acquired during the quarter who have an active subscription contract with us at the end of a fiscal quarter.

The Company’s ARR calculation utilizes the contract values in effect for active subscription contracts at the end of a fiscal quarter and as such, ARR reflects all actual reduction of fees due to contract non-renewals or cancellations that are effective as of the period-end date. Our ARR calculation is a point-in-time calculation that does not contemplate any anticipated non-renewals or cancellations for active contracts. As a result, we do not believe our ARR presents limitations as the calculation does not attempt to capture the probability of future changes in fee arrangements, non-renewals or cancellations of active contracts, and renewals of expired contracts.

The Company views Subscription Net Dollar Retention (“NDR”) as a more appropriate measure of customer renewal and expansion behavior as it measures how much ARR from the same cohort of customers existing at the start of a period increases or decreases over a 12 month period, considering expansions, net of contractions and churn. Specifically, our Subscription NDR is calculated by dividing the current fiscal year-end ARR by the corresponding prior year-end ARR, for those customers with an active ARR balance as of a year ago. Current fiscal year-end ARR (i.e., the numerator in the calculation) includes existing customer expansion, net of contraction and churn, but excludes new customers acquired in the current fiscal year period. The Company’s Subscription NDR was 120% and 117% for fiscal years ended 2024 and 2025. A subscription

NDR greater than 100% indicates that not only do the Company’s customers renew their contracts at a high rate, but they also renew at higher total subscription values.

ARR differs from GAAP revenue in that ARR is a point-in-time, contract value run-rate metric, whereas GAAP revenue for subscription services under ASC 606 is an accounting measure of revenue earned over time that follows the transfer of control of the underlying performance obligation(s) (e.g. ratably for subscription and support). In addition, ARR, for example, (i) excludes non-recurring revenue streams and one-time fees even though these items are included in GAAP revenue for subscription services and (ii) does not contemplate the proportionate allocation of the contracted subscription amounts to other performance obligations based on standalone selling prices for contracts that have multiple performance obligations or vice versa in accordance with ASC 606 that results in a decrease or increase to GAAP revenue for subscription services.

ARR is an informative metric as of a given point in time that measures the annualized recurring value of all active subscription contracts and on-demand billings based on most recent usage. ARR is not indicative of future revenue as ARR does not anticipate future events or circumstances such as (i) future non-renewals or cancellations of existing contracts or renewals of expired contracts, (ii) expansion, contraction and churn of existing customers or the acquisition of new customers, and (iii) changes in customers’ on-demand consumption of our subscription services. As noted on page 42 of our fiscal 2025 Form 10-K, ARR is a business metric and should be viewed independently of GAAP revenue and deferred revenue and is not intended to be a substitute for, or combined with, any of these items.

Revised Subscription ARR Disclosure

In response to the Staff’s comments, the Company will expand its disclosure of Subscription ARR within Management’s Discussion and Analysis of Financial Condition and Results of Operations beginning with its Form 10-Q filing for its second quarter ended August 3, 2025 as follows (bold, underline text represents additions; crossouts to text represents deletions to current disclosure):

Subscription Annualized Recurring Revenue (ARR)

We use Subscription ARR as a key business metric to evaluate the underlying performance of subscription services as of a point in time. Subscription ARR is not indicative of future revenue as events or circumstances that impact future revenue such as (i) future non-renewals or cancellations of existing contracts or renewals of expired contracts, (ii) expansion, contraction and churn of existing customers or the acquisition of new customers, and (iii) changes in customers’ on-demand consumption of our subscription services are not reflected in Subscription ARR. Subscription ARR should be viewed independently of revenue, deferred revenue and remaining performance obligations and is not intended as a substitute for any of these items.

Subscription ARR is calculated as the total annualized recurring contract value of all active, non-cancelable customer subscription agreements with subscription terms of any length at the end of a fiscal quarter, plus on-demand revenuebillings for the quarter multiplied by four. The cContract values are the contracted amounts in effect at the end of a fiscal quarter and do not contemplateestablished prior to any adjustments made in accordance with ASC 606 such as the proportionate allocation of the contracted subscription amounts to other performance obligations based on standalone selling prices for contracts that have multiple performance obligations or vice versa that are reflected in subscription services revenue under U.S. GAAP. On-demand billings represent billings for consumption by our customers’ most recent usage of our subscription services above the minimum usage commitment.

In addition, the Company intends to disclose, in future filings and on an annual basis, its Subscription NDR within Management’s Discussion and Analysis of Financial Condition and Results of Operations starting with its Form 10-K filing for the year ended February 1, 2026, in substantially the following form:

Subscription Net Dollar Retention (NDR)

We use Subscription Net Dollar Retention (NDR) as an indicator of our ability to successfully expand and grow revenue within our existing customer base on an annual basis. Our Subscription NDR, which approximates the year-over-year percentage growth in ARR from the same cohort of existing customers across comparable fiscal periods, was 117% and xx% for the fiscal years ended 2025 and 2026. Our Subscription NDR is calculated by dividing the current fiscal year-end ARR by the corresponding prior year-end ARR, for those customers with an active ARR balance as of a year ago. Current fiscal year-end ARR includes existing customer expansion, net of contraction and churn, but excludes ARR from new customers acquired in the current fiscal year period.

We believe that this expanded disclosure, in combination with other existing, relevant disclosures in our Form 10-K, provides a complete picture with respect to the ARR metric. Please contact me with any questions or comments regarding our response.

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You disclose pre-tax earnings from foreign operations of $18.0M, $41.96M and $63.56M in the 2020, 2021 and 2022 fiscal years in Note 15. You also disclose significant pre-tax losses from domestic operations of $212.67M, $312.12M and $192.06M in the 2020, 2021 and 2022 fiscal years in Note 15. You discuss your results on a consolidated basis and state that you have recorded no U.S.

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Federal current income tax and provided a full valuation allowance for U.S. deferred tax assets. However, it is unclear from your discussion what underlying factors are driving these disparate domestic and foreign operating results. Please discuss and analyze the factors driving your pre-tax earnings from foreign operations and your pre-tax losses from domestic operations. Also disclose qualitative and quantitative reasons for any material changes in results or known trends in your domestic and international operations. Refer to the guidance in Item 303 of Regulation S-K and SEC Release No. 33-8350.

We acknowledge the Staff’s comment, and we respectfully advise the Staff that the disparity between our domestic and foreign operating results in the periods presented in our annual report on Form 10-K is primarily due to the significant global pre-tax losses of our U.S. parent company and the intercompany transfer pricing arrangements for our international entities.

Our U.S. parent company owns the worldwide legal and economic rights to the Company’s intellectual property and bears most of the costs associated with our worldwide operations.

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Accordingly, significant pre-tax losses of the U.S. company are closely tied to our global pre-tax losses. Our foreign subsidiaries earn a guaranteed profit margin based on defined costs incurred by our foreign subsidiaries based on transfer pricing principles.

We expect the disparity between our domestic and foreign operating results would narrow over time if we are able to grow our global business and our U.S. pre-tax losses decline. Our foreign subsidiaries' sales and marketing expenses are expected to increase over time as we grow, which would result in higher intercompany transfer pricing revenue and therefore higher pre-tax foreign earnings.

In future filings, we will discuss and analyze material factors driving pre-tax earnings from our foreign operations and pre-tax losses from domestic operations. We will include disclosure, to the extent applicable, in future filings that provides the qualitative and quantitative reasons for any material changes in the Company’s results or known trends in domestic and international operations.

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You state on page 13 that, in addition to selling your products, your partners may offer installation, post-sale service and support on your behalf in their local markets. You identify Cisco and Microsoft as partners on pages 5 and 7. Both companies discussed sales to Syria and Sudan in publicly available letters to us in 2014.

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Syria and Sudan are designated by the State Department as state sponsors of terrorism, and are subject to U.S. economic sanctions and/or export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with Syria and Sudan, whether through subsidiaries, affiliates, distributors, joint venture partners, or other direct or indirect arrangements. You should describe any products, components, technology or services you have provided to Syria or Sudan, directly or indirectly, and any agreements, commercial arrangements or other contacts with the governments of those countries or entities they control.

650 Castro Street, Mountain View, CA 94041

Pure complies with applicable U.S. sanctions and export controls, and Pure has implemented and continues to maintain internal policies and measures designed to ensure compliance with applicable U.S. laws and regulations, including the sanctions programs administered by the U.S. Treasury Department’s Office of Foreign Assets Control and export controls administered by the U.S.

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Department of Commerce’s Bureau of Industry and Security.

Accordingly, Pure does not have any past or current contacts with Syria and Sudan, whether through subsidiaries, affiliates, distributors, joint venture partners, or other direct or indirect arrangements, and does not anticipate any future operations or contacts in these countries. Pure further confirms that, to its knowledge, Pure has not provided any products, components, technology or services to Syria or Sudan, directly or indirectly, and has had no agreements, commercial arrangements or other contacts with the governments of those countries or entities they control.

For background, Cisco and Microsoft are identified by Pure as technology partners. Pure works with its technology partners to test and pre-certify the interoperability of their respective application or infrastructure products, or to conduct co-marketing or lead-generation activities. Cisco and Microsoft do not sell, and are not obligated to provide, any installation, post-sale service and support for Pure’s products.

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