SEC Comment Letter for AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717) (T) — Oct 25, 2018
AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717)
Date: Oct. 25, 2018 · CIK: 0000732717 · Accession: 0000000000-18-033392
AI Filing Summary & Sentiment
File numbers found in text: 001-08610
Referenced dates: September 18, 2018
Letter
October 23, 2018 John J. Stephens Senior Executive Vice President and Chief Financial Officer AT&T Inc. 208 S. Akard St. Dallas, TX 75202 Re:AT&T Inc. Form 10-K for the Year Ended December 31, 2017 Form 10-Q for the Period Ended June 30, 2018 Response dated October 3, 2018 File No. 001-08610 Dear Mr. Stephens: We have reviewed your October 3, 2018 response to our comment letter and have the following comment. Please respond to this comment 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 this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 19, 2018 letter. Form 10-Q for the Period Ended June 30, 2018 Note 5. Revenue Recognition Service and Equipment Revenues, page 16 1.We note your responses to our comment letter dated September 18, 2018. Please revise your future filings to describe, as you do in your response to prior comment two, the nature of the specific goods and services that you consider separate performance obligations. For example, explain that you typically consider video service and the related equipment used to deliver that service to be a single performance obligation. Please also clarify that your equipment and service revenues are predominantly recognized on a gross basis. Please refer to ASC 606-10-50-12.
FirstName LastNameJohn J. Stephens Comapany NameAT&T Inc. October 23, 2018 Page 2 FirstName LastName John J. Stephens AT&T Inc. October 23, 2018 Page 2 You may contact Lisa Etheredge, Senior Staff Accountant at (202) 551-3424 or Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Telecommunications
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October 23, 2018
John J. Stephens
Senior Executive Vice President and Chief Financial Officer
AT&T Inc.
208 S. Akard St.
Dallas, TX 75202
Re:AT&T Inc.
Form 10-K for the Year Ended December 31, 2017
Form 10-Q for the Period Ended June 30, 2018
Response dated October 3, 2018
File No. 001-08610
Dear Mr. Stephens:
We have reviewed your October 3, 2018 response to our comment letter and have the
following comment. Please respond to this comment 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 this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
September 19, 2018 letter.
Form 10-Q for the Period Ended June 30, 2018
Note 5. Revenue Recognition
Service and Equipment Revenues, page 16
1.We note your responses to our comment letter dated September 18, 2018. Please revise
your future filings to describe, as you do in your response to prior comment two, the
nature of the specific goods and services that you consider separate performance
obligations. For example, explain that you typically consider video service and the related
equipment used to deliver that service to be a single performance obligation. Please also
clarify that your equipment and service revenues are predominantly recognized on a gross
basis. Please refer to ASC 606-10-50-12.
FirstName LastNameJohn J. Stephens
Comapany NameAT&T Inc.
October 23, 2018 Page 2
FirstName LastName
John J. Stephens
AT&T Inc.
October 23, 2018
Page 2
You may contact Lisa Etheredge, Senior Staff Accountant at (202) 551-3424 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications