SEC Comment Letter 0000000000-25-003511 to LEE ENTERPRISES, Inc (LEE)
LEE ENTERPRISES, Inc
Date: April 2, 2025 · CIK: 0000058361 · Accession: 0000000000-25-003511
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06227
Referenced dates: March 24, 2025
Letter
Re: Lee Enterprises, Incorporated Form 10-K for the Fiscal Year Ended September 29, 2024 Response Letter Dated March 24, 2025 File No. 001-06227 Dear Timothy Millage:
April 2, 2025
Timothy Millage Chief Financial Officer Lee Enterprises, Incorporated 4600 East 53rd Street Davenport, IA 52807
We have reviewed your March 24, 2025 response to our comment letter and have the following comment.
Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our February 24, 2025 letter.
Response Letter dated March 24, 2025 Response to Staff Comment 2
1. We note your response to prior comment 2. Please confirm that each of your 50 Strategic Business Units ("SBU's") represents a component and provide us with your assessment of the guidance in ASC 350-20-55-7(a)-(d) in determining that all SBU's have similar economic characteristics. Also tell us the discrete financial information that is available for each SBU, the quantitative data and metrics you considered in determining that your SBU's should be aggregated into a single reporting unit, and the high and low ends of the range for such quantitative datapoints of the component population for the periods used in your assessment. Please contact Melissa Gilmore at 202-551-3777 or Andrew Blume at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. April 2, 2025 Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing
Show Raw Text
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April 2, 2025
Timothy Millage
Chief Financial Officer
Lee Enterprises, Incorporated
4600 East 53rd Street
Davenport, IA 52807
Re: Lee Enterprises, Incorporated
Form 10-K for the Fiscal Year Ended September 29, 2024
Response Letter Dated March 24, 2025
File No. 001-06227
Dear Timothy Millage:
We have reviewed your March 24, 2025 response to our comment letter and
have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our February
24, 2025 letter.
Response Letter dated March 24, 2025
Response to Staff Comment 2
1. We note your response to prior comment 2. Please confirm that each of
your
50 Strategic Business Units ("SBU's") represents a component and provide
us with
your assessment of the guidance in ASC 350-20-55-7(a)-(d) in determining
that
all SBU's have similar economic characteristics. Also tell us the
discrete financial
information that is available for each SBU, the quantitative data and
metrics you
considered in determining that your SBU's should be aggregated into a
single
reporting unit, and the high and low ends of the range for such
quantitative datapoints
of the component population for the periods used in your assessment.
Please contact Melissa Gilmore at 202-551-3777 or Andrew Blume at
202-551-3254
if you have questions regarding comments on the financial statements and
related matters.
April 2, 2025
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing
</TEXT>
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