SEC Comment Letter 0000000000-23-013862 to Stagwell Inc (STGW) (CIK 0000876883) (STGW)
Stagwell Inc (STGW) (CIK 0000876883)
Date: Dec. 19, 2023 · CIK: 0000876883 · Accession: 0000000000-23-013862
AI Filing Summary & Sentiment
File numbers found in text: 001-13718
Letter
United States securities and exchange commission logo December 19, 2023 Frank Lanuto Chief Financial Officer Stagwell Inc. One World Trade Center, Floor 65 New York, NY 10007 Re:Stagwell Inc. Form 10-K for Fiscal Year Ended December 31, 2022 File No. 001-13718 Dear Frank Lanuto: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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. Form 10-K for Fiscal Year Ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Year Ended December 31, 2022 Compared to Year Ended December 31, 2021 Consolidated Results of Operations Net Revenue, page 47 1.Please clarify for us in further detail what the Net Acquisitions (Divestitures) and the organic revenue growth/decline change components represent and how they are calculated. If helpful, please provide a numerical example of the calculations. Notes to Consolidated Financial Statements 20. Segment Information, page 113 2.Given you generated approximately 17.5% of your total revenues outside of the United States in 2022 and maintain office space in Africa, Europe, Asia, South America, and Australia, please tell us your consideration of providing long-lived assets geographic
FirstName LastNameFrank Lanuto Comapany NameStagwell Inc. December 19, 2023 Page 2 FirstName LastName Frank Lanuto Stagwell Inc. December 19, 2023 Page 2 information in accordance with ASC 280-10-50-41, or revise. If providing this disclosure is impracticable (which is expected to be rare), please tell us the specific aspects of providing this disclosure that are impracticable and explain in detail why each aspect is impracticable. If your impracticability assertion for one or more specific aspects surrounds excessive cost, please also demonstrate how you determined the cost would be excessive. 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. Please contact Aamira Chaudhry at 202-551-3389 or Stephen Kim at 202-551-3291 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 19, 2023
Frank Lanuto
Chief Financial Officer
Stagwell Inc.
One World Trade Center, Floor 65
New York, NY 10007
Re:Stagwell Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 001-13718
Dear Frank Lanuto:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Year Ended December 31, 2022 Compared to Year Ended December 31, 2021
Consolidated Results of Operations
Net Revenue, page 47
1.Please clarify for us in further detail what the Net Acquisitions (Divestitures) and
the organic revenue growth/decline change components represent and how they are
calculated. If helpful, please provide a numerical example of the calculations.
Notes to Consolidated Financial Statements
20. Segment Information, page 113
2.Given you generated approximately 17.5% of your total revenues outside of the United
States in 2022 and maintain office space in Africa, Europe, Asia, South America, and
Australia, please tell us your consideration of providing long-lived assets geographic
FirstName LastNameFrank Lanuto
Comapany NameStagwell Inc.
December 19, 2023 Page 2
FirstName LastName
Frank Lanuto
Stagwell Inc.
December 19, 2023
Page 2
information in accordance with ASC 280-10-50-41, or revise. If providing this disclosure
is impracticable (which is expected to be rare), please tell us the specific aspects of
providing this disclosure that are impracticable and explain in detail why each aspect is
impracticable. If your impracticability assertion for one or more specific aspects surrounds
excessive cost, please also demonstrate how you determined the cost would be excessive.
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.
Please contact Aamira Chaudhry at 202-551-3389 or Stephen Kim at 202-551-3291 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services