SEC Comment Letter 0000000000-24-000750 to E.W. SCRIPPS Co (SSP) (CIK 0000832428) (SSP)
E.W. SCRIPPS Co (SSP) (CIK 0000832428)
Date: Jan. 19, 2024 · CIK: 0000832428 · Accession: 0000000000-24-000750
AI Filing Summary & Sentiment
File numbers found in text: 001-10701
Letter
United States securities and exchange commission logo January 19, 2024 Jason Combs Chief Financial Officer The E.W. Scripps Company 312 Walnut Street Cincinnati, OH 45202 Re:The E.W. Scripps Company Form 10-K for Fiscal Year Ended December 31, 2022 Form 8-K furnished November 3, 2023 File No. 001-10701 Dear Jason Combs: We have reviewed your December 21, 2023 response to our comment letter 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 a 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. Unless we note otherwise, any references to prior comments are to comments in our November 29, 2023 letter. Form 8-K furnished November 3, 2023 Exhibit 99.1, page 1 1.We note your response to prior comment 5. You state in your proposed revised disclosures that free cash flow is a measure of your ability to service debt, make investments and satisfy other obligations, which would appear to imply that this is a liquidity measure. In addition, you are deducting cash flows for items such as capital expenditures, preferred stock dividends, interest payments, income taxes paid (refunded) and mandatory contributions to retirement plans. Therefore, revise to reconcile such measure to the most directly comparable GAAP measure of operating cash flow. Also revise to relabel this measure (e.g. adjusted free cash flow) to more appropriately reflect what it represents. Lastly, while you state in your response that this metric is a universally used measure of valuation for broadcast television companies, please tell us and revise to explain in further detail how your management uses this measure in managing the business.
FirstName LastNameJason Combs Comapany NameThe E.W. Scripps Company January 19, 2024 Page 2 FirstName LastName Jason Combs The E.W. Scripps Company January 19, 2024 Page 2 Please contact Melissa Kindelan at 202-551-3564 or Kathleen Collins at 202-551-3499 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
January 19, 2024
Jason Combs
Chief Financial Officer
The E.W. Scripps Company
312 Walnut Street
Cincinnati, OH 45202
Re:The E.W. Scripps Company
Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K furnished November 3, 2023
File No. 001-10701
Dear Jason Combs:
We have reviewed your December 21, 2023 response to our comment letter 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 a
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. Unless
we note otherwise, any references to prior comments are to comments in our November 29,
2023 letter.
Form 8-K furnished November 3, 2023
Exhibit 99.1, page 1
1.We note your response to prior comment 5. You state in your proposed revised disclosures
that free cash flow is a measure of your ability to service debt, make investments and
satisfy other obligations, which would appear to imply that this is a liquidity measure. In
addition, you are deducting cash flows for items such as capital expenditures, preferred
stock dividends, interest payments, income taxes paid (refunded) and mandatory
contributions to retirement plans. Therefore, revise to reconcile such measure to the most
directly comparable GAAP measure of operating cash flow. Also revise to relabel this
measure (e.g. adjusted free cash flow) to more appropriately reflect what it represents.
Lastly, while you state in your response that this metric is a universally used measure of
valuation for broadcast television companies, please tell us and revise to explain in further
detail how your management uses this measure in managing the business.
FirstName LastNameJason Combs
Comapany NameThe E.W. Scripps Company
January 19, 2024 Page 2
FirstName LastName
Jason Combs
The E.W. Scripps Company
January 19, 2024
Page 2
Please contact Melissa Kindelan at 202-551-3564 or Kathleen Collins at 202-551-3499 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology