SEC Comment Letter 0000000000-23-002602 to Paramount Global (PARA, PARAA) (CIK 0000813828)
Paramount Global (PARA, PARAA) (CIK 0000813828)
Date: March 16, 2023 · CIK: 0000813828 · Accession: 0000000000-23-002602
AI Filing Summary & Sentiment
File numbers found in text: 001-09553
Letter
United States securities and exchange commission logo March 16, 2023 Naveen Chopra Chief Financial Officer Paramount Global 1515 Broadway New York, New York 10036 Re:Paramount Global Form 10-K for the Fiscal Year Ended December 31, 2022 File No. 001-09553 Filed February 16, 2023 Dear Naveen Chopra: We have reviewed your filing and have the following 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. Form 10-K for the Fiscal Year Ended December 31, 2022 Critical Accounting Policies Goodwill and Intangible Assets Impairment Tests, page II-37 1.It appears that your goodwill balance exceeds your market capitalization. Tell us and disclose how you considered market capitalization when performing your goodwill impairment testing.
2.Given the significant balance of your goodwill and significant judgments involving goodwill impairment testing, please consider disclosing in future filings the balance of goodwill for each reporting unit.
3.Tell us why the fourth quarter 2022 management reorganization resulted in a change to your reporting units within the TV Media segment. Also, explain in further detail why a
FirstName LastNameNaveen Chopra Comapany NameParamount Global March 16, 2023 Page 2 FirstName LastName Naveen Chopra Paramount Global March 16, 2023 Page 2 quantitative impairment test was not performed for each reporting unit prior to and post the fourth quarter reorganization. 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. You may contact Inessa Kessman, Senior Staff Accountant, at 202-551-3371 or Robert Littlepage, Accounting Branch Chief, at 202-551-3361 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
March 16, 2023
Naveen Chopra
Chief Financial Officer
Paramount Global
1515 Broadway
New York, New York 10036
Re:Paramount Global
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 001-09553
Filed February 16, 2023
Dear Naveen Chopra:
We have reviewed your filing and have the following 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.
Form 10-K for the Fiscal Year Ended December 31, 2022
Critical Accounting Policies
Goodwill and Intangible Assets Impairment Tests, page II-37
1.It appears that your goodwill balance exceeds your market capitalization. Tell us and
disclose how you considered market capitalization when performing your goodwill
impairment testing.
2.Given the significant balance of your goodwill and significant judgments involving
goodwill impairment testing, please consider disclosing in future filings the balance of
goodwill for each reporting unit.
3.Tell us why the fourth quarter 2022 management reorganization resulted in a change to
your reporting units within the TV Media segment. Also, explain in further detail why a
FirstName LastNameNaveen Chopra
Comapany NameParamount Global
March 16, 2023 Page 2
FirstName LastName
Naveen Chopra
Paramount Global
March 16, 2023
Page 2
quantitative impairment test was not performed for each reporting unit prior to and post
the fourth quarter reorganization.
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.
You may contact Inessa Kessman, Senior Staff Accountant, at 202-551-3371 or Robert
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology