Correspondence 0000071691-23-000040 from NEW YORK TIMES CO (NYT) (CIK 0000071691) (NYT)
NEW YORK TIMES CO (NYT) (CIK 0000071691)
Date: Dec. 8, 2023 · CIK: 0000071691 · Accession: 0000071691-23-000040
AI Filing Summary & Sentiment
File numbers found in text: 001-05837
Referenced dates: November 27, 2023
Letter
Document
William Bardeen
Executive Vice President and
Chief Financial Officer
T 212 556 7001
bardewt@nytimes.com
620 8th Avenue
New York, NY 10018
December 8, 2023
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Re: The New York Times Company
Form 10-K for the Year Ended December 31, 2022
Filed February 28, 2023
File No. 001-05837
Ladies and Gentlemen:
The following sets out the response of The New York Times Company (the “Company”, “we”, “us” or “our”) to the comment set forth in your letter dated November 27, 2023, regarding the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 (the “2022 10-K”). For ease of review, we have set out the comment together with the Company’s response.
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.
Securities and Exchange Commission
December 8, 2023
Page 2
Response:
We acknowledge the Staff’s comment and will update future interim and annual filings to also reconcile adjusted operating costs by individual segment to the corresponding GAAP measure. This expanded reconciliation will be substantially as follows:
Years Ended
December 31, 2022 December 26, 2021
(52 weeks and six days)(1)
(52 weeks)
(in thousands) NYTG The Athletic Consolidated NYTG The Athletic Consolidated
Total operating costs $ 1,955,169 $ 151,185 $ 2,106,354 $ 1,806,843 $ — $ 1,806,843
Less:
Depreciation and amortization 57,392 25,262 82,654 57,502 — 57,502
Severance 4,509 160 4,669 882 — 882
Multiemployer pension plan withdrawal costs 4,871 — 4,871 5,150 — 5,150
Acquisition-related costs 34,712 — 34,712 — — —
Multiemployer pension plan liability adjustment 14,989 — 14,989 — — —
Impairment charge 4,069 — 4,069 — — —
Lease termination charge — — — 3,831 — 3,831
Total adjusted operating costs $ 1,834,627 $ 125,763 $ 1,960,390 $ 1,739,478 $ — $ 1,739,478
(1) The results of The Athletic have been included in our Consolidated Financial Statements beginning February 1, 2022.
____________________
If there are any questions, please contact the undersigned at 212-556-7001, or Diane Brayton, Executive Vice President and General Counsel, at 212-556-5995.
Very truly yours,
/s/ William Bardeen
Show Raw Text
CORRESP 1 filename1.htm Document William Bardeen Executive Vice President and Chief Financial Officer T 212 556 7001 bardewt@nytimes.com 620 8th Avenue New York, NY 10018 December 8, 2023 Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Re: The New York Times Company Form 10-K for the Year Ended December 31, 2022 Filed February 28, 2023 File No. 001-05837 Ladies and Gentlemen: The following sets out the response of The New York Times Company (the “Company”, “we”, “us” or “our”) to the comment set forth in your letter dated November 27, 2023, regarding the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 (the “2022 10-K”). For ease of review, we have set out the comment together with the Company’s response. 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. Securities and Exchange Commission December 8, 2023 Page 2 Response: We acknowledge the Staff’s comment and will update future interim and annual filings to also reconcile adjusted operating costs by individual segment to the corresponding GAAP measure. This expanded reconciliation will be substantially as follows: Years Ended December 31, 2022 December 26, 2021 (52 weeks and six days)(1) (52 weeks) (in thousands) NYTG The Athletic Consolidated NYTG The Athletic Consolidated Total operating costs $ 1,955,169 $ 151,185 $ 2,106,354 $ 1,806,843 $ — $ 1,806,843 Less: Depreciation and amortization 57,392 25,262 82,654 57,502 — 57,502 Severance 4,509 160 4,669 882 — 882 Multiemployer pension plan withdrawal costs 4,871 — 4,871 5,150 — 5,150 Acquisition-related costs 34,712 — 34,712 — — — Multiemployer pension plan liability adjustment 14,989 — 14,989 — — — Impairment charge 4,069 — 4,069 — — — Lease termination charge — — — 3,831 — 3,831 Total adjusted operating costs $ 1,834,627 $ 125,763 $ 1,960,390 $ 1,739,478 $ — $ 1,739,478 (1) The results of The Athletic have been included in our Consolidated Financial Statements beginning February 1, 2022. ____________________ If there are any questions, please contact the undersigned at 212-556-7001, or Diane Brayton, Executive Vice President and General Counsel, at 212-556-5995. Very truly yours, /s/ William Bardeen William Bardeen Executive Vice President and Chief Financial Officer (Principal Financial Officer) cc: Diane Brayton, The New York Times Company Andrew Blume, SEC Staff Claire Erlanger, SEC Staff Morgan, Lewis & Bockius LLP Ernst & Young, LLP