SEC Comment Letter 0000000000-24-010661 to Graham Holdings Co (GHC) (CIK 0000104889) (GHC)
Graham Holdings Co (GHC) (CIK 0000104889)
Date: Sept. 19, 2024 · CIK: 0000104889 · Accession: 0000000000-24-010661
AI Filing Summary & Sentiment
File numbers found in text: 001-06714
Letter
September 19, 2024 Wallace R. Cooney Chief Financial Officer Graham Holdings Company 1300 North 17th Street Arlington, VA 22209 Re:Graham Holdings Company Form 10-K for the Year Ended December 31, 2023 File No. 001-06714 Dear Wallace R. Cooney: We have reviewed your filing 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 the 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. Form 10-K for the Year Ended December 31, 2023 Item 11. Executive Compensation, page 46 1.From the disclosure incorporated by reference from page 18 of the Definitive Proxy Statement filed on March 26, 2024, it appears that you have not provided your disclosure about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a recovery analysis, please also include the interactive data. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
September 19, 2024 Page 2 Please contact Robert Arzonetti at 202-551-8819 or Sebastian Gomez Abero at 202-551- 3578 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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September 19, 2024
Wallace R. Cooney
Chief Financial Officer
Graham Holdings Company
1300 North 17th Street
Arlington, VA 22209
Re:Graham Holdings Company
Form 10-K for the Year Ended December 31, 2023
File No. 001-06714
Dear Wallace R. Cooney:
We have reviewed your filing 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 the
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.
Form 10-K for the Year Ended December 31, 2023
Item 11. Executive Compensation, page 46
1.From the disclosure incorporated by reference from page 18 of the Definitive Proxy
Statement filed on March 26, 2024, it appears that you have not provided your disclosure
about your recovery analysis in an Interactive Data File in accordance with Rule 405 of
Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a
recovery analysis, please also include the interactive data.
We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of action
by the staff.
September 19, 2024
Page 2
Please contact Robert Arzonetti at 202-551-8819 or Sebastian Gomez Abero at 202-551-
3578 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance