SEC Comment Letter for LEE ENTERPRISES, Inc (LEE) (CIK 0000058361) (LEE) — Feb 5, 2013
LEE ENTERPRISES, Inc (LEE) (CIK 0000058361)
Date: Feb. 5, 2013 · CIK: 0000058361 · Accession: 0000000000-13-006515
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06227
Referenced dates: January 11, 2013, January 3, 2013
Letter
February 5 , 2013 Via E-Mail Mr. Carl G. Schmidt Chief Financial Officer Lee Enterprises Inc. 201 North Harrison Street Suite 600 Davenport, IA 52801 -1939
Re: Lee Enterprises , Inc. Form 10-K for the year ended September 30, 2012 Filed December 14 , 2012 File No. 001-06227
Dear Mr. Schmidt :
We have reviewed your letter dated January 11, 2013 , in response to the Staff’s letter dated January 3, 2013 and have the following additional comment. Please revise your disclosure in future filings in response to our comment. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond within ten (10) business days.
Note 16. Commitments and Contingent Liabilities Redemption of PD LLC Minority Interest, page 81
1. We note your response to our prior comment number 10 in which you indicate that the change in the liability associated with the Herald Value was recognized as a component of other income (expense) in your consolidated statement of operations. Please explain in further detail why you believe it was appropriate to reflect the reduction of this liability in your consolidated statement of operations rather than as an equity transaction consistent with the treatment of the other transactions recognized in connection with the redemption of Herald’s interest in PD LLC and DS LLC as further described in Note 16 to your financial statements. We may have further comment upon review of your response.
Mr. Carl G. Schmidt Lee Enterprises Inc. February 5 , 2013 Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, the undersigned at (202) 551 -3750 if you have questions regarding comments on the financial statements and related matters. Please contact the undersigned at (202) 551 -3750 with any other questions.
Sincerely,
/s/ Linda Cvrkel
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February 5 , 2013 Via E-Mail Mr. Carl G. Schmidt Chief Financial Officer Lee Enterprises Inc. 201 North Harrison Street Suite 600 Davenport, IA 52801 -1939 Re: Lee Enterprises , Inc. Form 10-K for the year ended September 30, 2012 Filed December 14 , 2012 File No. 001-06227 Dear Mr. Schmidt : We have reviewed your letter dated January 11, 2013 , in response to the Staff’s letter dated January 3, 2013 and have the following additional comment. Please revise your disclosure in future filings in response to our comment. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond within ten (10) business days. Note 16. Commitments and Contingent Liabilities Redemption of PD LLC Minority Interest, page 81 1. We note your response to our prior comment number 10 in which you indicate that the change in the liability associated with the Herald Value was recognized as a component of other income (expense) in your consolidated statement of operations. Please explain in further detail why you believe it was appropriate to reflect the reduction of this liability in your consolidated statement of operations rather than as an equity transaction consistent with the treatment of the other transactions recognized in connection with the redemption of Herald’s interest in PD LLC and DS LLC as further described in Note 16 to your financial statements. We may have further comment upon review of your response. Mr. Carl G. Schmidt Lee Enterprises Inc. February 5 , 2013 Page 2 You may contact Effie Simpson at (202) 551 -3346 , or in her absence, the undersigned at (202) 551 -3750 if you have questions regarding comments on the financial statements and related matters. Please contact the undersigned at (202) 551 -3750 with any other questions. Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief