SEC Comment Letter for Stagwell Inc (STGW) (CIK 0000876883) (STGW) — Sep 19, 2018
Stagwell Inc (STGW) (CIK 0000876883)
Date: Sept. 19, 2018 · CIK: 0000876883 · Accession: 0000000000-18-029454
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13718
Letter
September 19, 2018 David Doft Chief Financial Officer MDC Partners Inc. 745 Fifth Avenue New York, NY 10151 Re:MDC Partners Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 1, 2018 Form 10-Q for the Quarterly Period Ended June 30, 2018 Filed August 7, 2018 File No. 001-13718 Dear Mr. Doft: We have limited our review of your filing to the financial statements and related disclosures 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-Q for the Quarterly Period Ended June 30, 2018 Notes to Unaudited Condensed Consolidated Financial Statements Revenue, page 8 1.Tell us how you determined that you act as agent for your production and media buying services. Please specifically address how you considered your role, if any, in creating or developing a client's marketing or corporate communications message. Refer to ASC 606-10-55-36 through 40 and ASC 606-10-50-12(c). 2.We note the nature of services performed by each of your reportable segments as described on pages 20-21. Please tell us which services you combine with others for the
FirstName LastNameDavid Doft Comapany NameMDC Partners Inc. September 19, 2018 Page 2 FirstName LastName David Doft MDC Partners Inc. September 19, 2018 Page 2 purposes of determining your performance obligations and which services you treat as a separate performance obligation. Refer to ASC 606-10-25-21 and ASC 606-10-50-12(c). In closing, 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 Kathryn Jacobson,, Senior Staff Accountant at (202) 551-3365 or Robert S. Littlepage, Accountant Branch Chief at (202) 551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Telecommunications
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September 19, 2018
David Doft
Chief Financial Officer
MDC Partners Inc.
745 Fifth Avenue
New York, NY 10151
Re:MDC Partners Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 1, 2018
Form 10-Q for the Quarterly Period Ended June 30, 2018
Filed August 7, 2018
File No. 001-13718
Dear Mr. Doft:
We have limited our review of your filing to the financial statements and related
disclosures 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-Q for the Quarterly Period Ended June 30, 2018
Notes to Unaudited Condensed Consolidated Financial Statements
Revenue, page 8
1.Tell us how you determined that you act as agent for your production and media buying
services. Please specifically address how you considered your role, if any, in creating or
developing a client's marketing or corporate communications message. Refer to ASC
606-10-55-36 through 40 and ASC 606-10-50-12(c).
2.We note the nature of services performed by each of your reportable segments as
described on pages 20-21. Please tell us which services you combine with others for the
FirstName LastNameDavid Doft
Comapany NameMDC Partners Inc.
September 19, 2018 Page 2
FirstName LastName
David Doft
MDC Partners Inc.
September 19, 2018
Page 2
purposes of determining your performance obligations and which services you treat as a
separate performance obligation. Refer to ASC 606-10-25-21 and ASC 606-10-50-12(c).
In closing, 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 Kathryn Jacobson,, Senior Staff Accountant at (202) 551-3365 or
Robert S. Littlepage, Accountant Branch Chief at (202) 551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications