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SEC Comment Letter for HASBRO, INC. (HAS) (CIK 0000046080) (HAS) — Sep 11, 2018

HASBRO, INC. (HAS) (CIK 0000046080)
Date: Sept. 11, 2018 · CIK: 0000046080 · Accession: 0000000000-18-028038

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Reasoning

File numbers found in text: 001-06682

Date
September 6, 2018
Author
Heather Clark
Form
UPLOAD
Company
HASBRO, INC. (HAS) (CIK 0000046080)

Letter

September 6, 2018 Deborah Thomas Chief Financial Officer Hasbro, Inc. 1027 Newport Avenue Pawtucket, Rhode Island 02861 Re:Hasbro, Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Form 10-Q for the Fiscal Quarter Ended July 1, 2018 File No. 001-06682 Dear Ms. Thomas: We have reviewed your August 14, 2018 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 3, 2018 letter. Form 10-Q for the Fiscal Quarter Ended July 1, 2018 Financial Statements Condensed Notes to Consolidated Financial Statements (9) Pension and Postretirement Benefits, page 1 1.We note your response to our prior comment 1 and the disclosure in the Form 10-Q for the quarter ended July 1, 2018 which indicates that upon settlement of the pension liability, you will reclassify the related pension losses currently recorded to accumulated other comprehensive loss, to the consolidated statements of operations. Please tell us, and revise your disclosure to indicate the estimated amount of net unrealized losses that you expect to recognize upon settlement. You may preface the amount by indicating that the

FirstName LastNameDeborah Thomas Comapany NameHasbro, Inc. September 6, 2018 Page 2 FirstName LastName Deborah Thomas Hasbro, Inc. September 6, 2018 Page 2 actual amount may differ due to changes in interest rates, pension plan asset returns and other factors. You may contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with any questions. Sincerely, Division of Corporation Finance Office of Transportation and Leisure

Show Raw Text
September 6, 2018
Deborah Thomas
Chief Financial Officer
Hasbro, Inc.
1027 Newport Avenue
Pawtucket, Rhode Island 02861
Re:Hasbro, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Form 10-Q for the Fiscal Quarter Ended July 1, 2018
File No. 001-06682
Dear Ms. Thomas:
            We have reviewed your August 14, 2018 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
August 3, 2018 letter.
Form 10-Q for the Fiscal Quarter Ended July 1, 2018
Financial Statements
Condensed Notes to Consolidated Financial Statements
(9) Pension and Postretirement Benefits, page 1
1.We note your response to our prior comment 1 and the disclosure in the Form 10-Q for the
quarter ended July 1, 2018 which indicates that upon settlement of the pension liability,
you will reclassify the related pension losses currently recorded to accumulated other
comprehensive loss, to the consolidated statements of operations.  Please tell us, and
revise your disclosure to indicate the estimated amount of net unrealized losses that you
expect to recognize upon settlement.  You may preface the amount by indicating that the

 FirstName LastNameDeborah Thomas
 Comapany NameHasbro, Inc.
 September 6, 2018 Page 2
 FirstName LastName
Deborah Thomas
Hasbro, Inc.
September 6, 2018
Page 2
actual amount may differ due to changes in interest rates, pension plan asset returns and
other factors.
            You may contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure