SEC Comment Letter 0000000000-23-012852 to NEW YORK TIMES CO (NYT) (CIK 0000071691) (NYT)
NEW YORK TIMES CO (NYT) (CIK 0000071691)
Date: Nov. 27, 2023 · CIK: 0000071691 · Accession: 0000000000-23-012852
AI Filing Summary & Sentiment
File numbers found in text: 001-05837
Letter
United States securities and exchange commission logo November 27, 2023 Roland Caputo Chief Financial Officer The New York Times Company 620 Eighth Ave New York, NY 10018 Re:The New York Times Company Form 10-K for the Fiscal Year Ended December 31, 2022 Response Dated October 18, 2023 File No. 001-05837 Dear Roland Caputo: We have reviewed your October 18, 2023 response to our comment letter and have the following comment. 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 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 September 19, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 16. Segment Information, page 111 1.We note your response to comment 5 and the expanded non-GAAP reconciliation for consolidated adjusted operating costs that you intend to include in future filings. Please further revise your proposed disclosures to also reconcile adjusted operating costs by individual segment to the corresponding GAAP measure. The reconciliation should include detail of all significant adjusting amounts.
FirstName LastNameRoland Caputo Comapany NameThe New York Times Company November 27, 2023 Page 2 FirstName LastName Roland Caputo The New York Times Company November 27, 2023 Page 2 Please contact Andrew Blume at 202-551-3254 or Claire Erlanger at 202-551-3301 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Will Bardeen
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United States securities and exchange commission logo
November 27, 2023
Roland Caputo
Chief Financial Officer
The New York Times Company
620 Eighth Ave
New York, NY 10018
Re:The New York Times Company
Form 10-K for the Fiscal Year Ended December 31, 2022
Response Dated October 18, 2023
File No. 001-05837
Dear Roland Caputo:
We have reviewed your October 18, 2023 response to our comment letter and have the
following comment.
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 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 September 19, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
16. Segment Information, page 111
1.We note your response to comment 5 and the expanded non-GAAP reconciliation for
consolidated adjusted operating costs that you intend to include in future filings. Please
further revise your proposed disclosures to also reconcile adjusted operating costs by
individual segment to the corresponding GAAP measure. The reconciliation should
include detail of all significant adjusting amounts.
FirstName LastNameRoland Caputo
Comapany NameThe New York Times Company
November 27, 2023 Page 2
FirstName LastName
Roland Caputo
The New York Times Company
November 27, 2023
Page 2
Please contact Andrew Blume at 202-551-3254 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Will Bardeen