SEC Comment Letter for Activision Blizzard, Inc. (CIK 0000718877) — Mar 2, 2022
Activision Blizzard, Inc. (CIK 0000718877)
Date: March 2, 2022 · CIK: 0000718877 · Accession: 0000000000-22-002360
AI Filing Summary & Sentiment
File numbers found in text: 001-15839
Letter
United States securities and exchange commission logo March 2, 2022 Robert A. Kotick Chief Executive Officer Activision Blizzard, Inc. 3100 Ocean Park Boulevard Santa Monica, California 90405 Re:Activision Blizzard, Inc. Preliminary Proxy Statement on Schedule 14A Filed February 18, 2022 File No. 001-15839 Dear Mr. Kotick: We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Preliminary Proxy Statement on Schedule 14A General 1.Given recent press reports describing labor and employment disputes, including unionization efforts by your employees, please tell us the impact that these events have, or are expected to have, on the representations and warranties contained in the merger agreement. 2.We note that the merger agreement references a disclosure letter. Please supplementally provide us with a list briefly identifying the contents of the disclosure letter. In this regard, please be advised that information contained in schedules or similar supplements should be disclosed in the proxy statement if the information would be material to an investment decision and is required to make other information disclosed not misleading.
FirstName LastNameRobert A. Kotick Comapany NameActivision Blizzard, Inc. March 2, 2022 Page 2 FirstName LastName Robert A. Kotick Activision Blizzard, Inc. March 2, 2022 Page 2 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. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or Joshua Shainess, Legal Branch Chief, at (202) 551-7951 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Sonia K. Nijjar, Esq.
Show Raw Text
United States securities and exchange commission logo
March 2, 2022
Robert A. Kotick
Chief Executive Officer
Activision Blizzard, Inc.
3100 Ocean Park Boulevard
Santa Monica, California 90405
Re:Activision Blizzard, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed February 18, 2022
File No. 001-15839
Dear Mr. Kotick:
We have limited our review of your registration statement to those issues we have
addressed in our comments. In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
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 our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Preliminary Proxy Statement on Schedule 14A
General
1.Given recent press reports describing labor and employment disputes,
including unionization efforts by your employees, please tell us the impact that these
events have, or are expected to have, on the representations and warranties contained in
the merger agreement.
2.We note that the merger agreement references a disclosure letter. Please supplementally
provide us with a list briefly identifying the contents of the disclosure letter. In this
regard, please be advised that information contained in schedules or similar supplements
should be disclosed in the proxy statement if the information would be material to an
investment decision and is required to make other information disclosed not misleading.
FirstName LastNameRobert A. Kotick
Comapany NameActivision Blizzard, Inc.
March 2, 2022 Page 2
FirstName LastName
Robert A. Kotick
Activision Blizzard, Inc.
March 2, 2022
Page 2
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.
Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or Joshua Shainess,
Legal Branch Chief, at (202) 551-7951 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Sonia K. Nijjar, Esq.