SEC Comment Letter for LEE ENTERPRISES, Inc (LEE) (CIK 0000058361) (LEE) — Mar 5, 2019
LEE ENTERPRISES, Inc (LEE) (CIK 0000058361)
Date: March 5, 2019 · CIK: 0000058361 · Accession: 0000000000-19-003841
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06227
Letter
March 5, 2019 Timothy R. Millage 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 30, 2018 Filed December 14, 2018 File No. 001-06227 Dear Mr. Millage: We have reviewed your February 28, 2019 response to our comment letter 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 business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment 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. Unless we note otherwise, our references to prior comments are to comments in our February 14, 2019 letter. Form 10-K for the Fiscal Year Ended September 30, 2018 Management's Discussion and Analysis of Financial Condition and Results of Operations Continuing Operations, page 25 1.We note the reconciliation you plan to include in future filings related to prior comment 1. In light of the fact that you will now be disclosing same property amounts, rather than percentages, please also revise to clarify that these same property basis amounts are non GAAP measures, and include a statement as to why management believes the measure is useful to investors. Refer to Item 10(e)(i)(C) of Regulation S-K. Also, we note that the discussion of revenue comparison between 2017 and 2016 on page 26, appears to be only on a same property basis. Please note that MD&A should include a discussion of all significant changes in revenue on a GAAP basis, and may be supplemented by a discussion of non-GAAP amounts, assuming the appropriate disclosures required by Item
FirstName LastNameTimothy R. Millage Comapany NameLee Enterprises, Incorporated March 5, 2019 Page 2 FirstName LastName Timothy R. Millage Lee Enterprises, Incorporated March 5, 2019 Page 2 10(e) of Regulation G are included. 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
March 5, 2019
Timothy R. Millage
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 30, 2018
Filed December 14, 2018
File No. 001-06227
Dear Mr. Millage:
We have reviewed your February 28, 2019 response to our comment letter 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 business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment 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. Unless we note otherwise, our references to prior comments are to comments in our
February 14, 2019 letter.
Form 10-K for the Fiscal Year Ended September 30, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Continuing Operations, page 25
1.We note the reconciliation you plan to include in future filings related to prior comment
1. In light of the fact that you will now be disclosing same property amounts, rather than
percentages, please also revise to clarify that these same property basis amounts are non
GAAP measures, and include a statement as to why management believes the measure is
useful to investors. Refer to Item 10(e)(i)(C) of Regulation S-K. Also, we note that the
discussion of revenue comparison between 2017 and 2016 on page 26, appears to be only
on a same property basis. Please note that MD&A should include a discussion of all
significant changes in revenue on a GAAP basis, and may be supplemented by a
discussion of non-GAAP amounts, assuming the appropriate disclosures required by Item
FirstName LastNameTimothy R. Millage
Comapany NameLee Enterprises, Incorporated
March 5, 2019 Page 2
FirstName LastName
Timothy R. Millage
Lee Enterprises, Incorporated
March 5, 2019
Page 2
10(e) of Regulation G are included.
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