SEC Comment Letter for LEE ENTERPRISES, Inc (LEE) (CIK 0000058361) (LEE) — Jun 6, 2016
LEE ENTERPRISES, Inc (LEE) (CIK 0000058361)
Date: June 6, 2016 · CIK: 0000058361 · Accession: 0000000000-16-079344
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 20, 2016
Letter
Mail Stop 3561 June 6 , 2016 Ronald A. Mayo Chief Financial Officer Lee Enterprises, Incorporated 201 N. Harrison Street, Suite 600 Davenport, Iowa 52801
Re: Lee Enterprises, Incorporated Form 10-K for the Fiscal Year Ended September 27, 2015 Filed December 11, 2015 File No. 001 -06227
Dear Mr. Mayo :
We have reviewed your response letter dated May 20, 2016 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comm ent 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 September 27, 2015
Critical Accounting P olicies, page 23
1. We note from your response to our prior comment 2 that along with WACC, cash flow projections is one of the main drivers for determining fair value under the income approach and it involves significant estimates and assumptions, such as f uture revenue, cash costs, operating margins and the period over which future cash flow are projected. You also indicate in your response that such projections take into a ccount historical trends, anticipated future results from the annual budgeting proces s as well as projections from published analyst reports; however, you do not provide key assumptions or estimates or how such amounts were calculated or determined, specific to Lee Enterprises. Therefore , we reissue our comment in part. Please provide us with the key assumptions used in your goodwill impairment analysis. Additionally, for each key assumption or estimate used in your cash flow projections please provide us the basis which supports each of your key assumptions or estimates, why management believe it is reasonable and appropriate, and the level of uncertainty associated with each.
Ronald A. Mayo Lee Enterprises, Incorporated June 6, 2016 Page 2
You may contact Heather Clark at 202 -551-3624 or Jean Yu at 202 -551-3305 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3377 with any other questions.
Sincerely,
/s/ Andrew Mew
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Mail Stop 3561
June 6 , 2016
Ronald A. Mayo
Chief Financial Officer
Lee Enterprises, Incorporated
201 N. Harrison Street, Suite 600
Davenport, Iowa 52801
Re: Lee Enterprises, Incorporated
Form 10-K for the Fiscal Year Ended September 27, 2015
Filed December 11, 2015
File No. 001 -06227
Dear Mr. Mayo :
We have reviewed your response letter dated May 20, 2016 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 busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comm ent 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 September 27, 2015
Critical Accounting P olicies, page 23
1. We note from your response to our prior comment 2 that along with WACC, cash flow
projections is one of the main drivers for determining fair value under the income
approach and it involves significant estimates and assumptions, such as f uture revenue,
cash costs, operating margins and the period over which future cash flow are projected.
You also indicate in your response that such projections take into a ccount historical
trends, anticipated future results from the annual budgeting proces s as well as projections
from published analyst reports; however, you do not provide key assumptions or
estimates or how such amounts were calculated or determined, specific to Lee
Enterprises. Therefore , we reissue our comment in part. Please provide us with the key
assumptions used in your goodwill impairment analysis. Additionally, for each key
assumption or estimate used in your cash flow projections please provide us the basis
which supports each of your key assumptions or estimates, why management believe it is
reasonable and appropriate, and the level of uncertainty associated with each.
Ronald A. Mayo
Lee Enterprises, Incorporated
June 6, 2016
Page 2
You may contact Heather Clark at 202 -551-3624 or Jean Yu at 202 -551-3305 if you have
questions regarding comments on the financial statements and related matters. Please contact me
at 202 -551-3377 with any other questions.
Sincerely,
/s/ Andrew Mew
Andrew Mew
Senior Assistant Chief Accountant
Office of Transportation and Leisure