SEC Comment Letter for Match Group, Inc. (MTCH) (CIK 0000891103) (MTCH) — Jun 8, 2007
Match Group, Inc. (MTCH) (CIK 0000891103)
Date: June 8, 2007 · CIK: 0000891103 · Accession: 0000000000-07-028308
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-20570
Referenced dates: June 4, 2007
Letter
Mail Stop 3561 June 8, 2007 Via Fax & U.S. Mail Mr. Thomas J. McInerney Executive Vice President and Chief Financial Officer 152 West 57th Street New York, New York 10019
Re: IAC/INTERACTIVECORP Form 10-K for the year ended December 31, 2006 Filed March 1, 2007 File No. 000-20570
Dear Mr. McInerney:
We have reviewed your response letter dated June 4, 2007 and have the following comments. Unless otherwise indicated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please be as detailed as necessary in your explanat ion. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Please respond to confirm that such comments will be complied with, or, if certain of the comments are deemed inappropr iate, advise the staff of your reason. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond w ithin ten (10) business days.
Form 10-K for the year ended December 31, 2006
Notes to the Financial Statements
Note 2. Summary of Significant Accounting Policies
Mr. Thomas J. McInerney IAC/INTERACTIVECORP June 8, 2007 Page 2
- Revenue Recognition, page 77
1. We note from your response to our prior comment 1 that you recognize revenue for domestic electronic retailing transact ions at the time of shipment because you believe that title and risk of loss pass to the buyer at this point. Please revise your disclosure in the notes to the financia l statements to clarify why you recognize revenue at the time of shipment for thes e transactions and why you believe this accounting policy is in acco rdance with SAB 104.
********
You may contact Claire Erlanger at (202) 551-3301 if you have questions regarding comments on the financia l statements and related matte rs. Please contact me at (202) 551-3813 with any other questions.
Sincerely,
Linda Cvrkel
Branch Chief
Show Raw Text
Mail Stop 3561
June 8, 2007
Via Fax & U.S. Mail
Mr. Thomas J. McInerney
Executive Vice President and Chief Financial Officer
152 West 57th Street
New York, New York 10019
Re: IAC/INTERACTIVECORP
Form 10-K for the year ended December 31, 2006
Filed March 1, 2007
File No. 000-20570
Dear Mr. McInerney:
We have reviewed your response letter dated June 4, 2007 and have the following
comments. Unless otherwise indicated, we think you should revise your document in
future filings in response to these comments. If you disagree, we will consider your
explanation as to why our comment is inappl icable or a revision is unnecessary. Please
be as detailed as necessary in your explanat ion. In some of our comments, we may ask
you to provide us with information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Please respond to confirm that such comments will be complied with, or, if
certain of the comments are deemed inappropr iate, advise the staff of your reason. Your
response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond w ithin ten (10) business days.
Form 10-K for the year ended December 31, 2006
Notes to the Financial Statements
Note 2. Summary of Significant Accounting Policies
Mr. Thomas J. McInerney
IAC/INTERACTIVECORP
June 8, 2007 Page 2
- Revenue Recognition, page 77
1. We note from your response to our prior comment 1 that you recognize revenue
for domestic electronic retailing transact ions at the time of shipment because you
believe that title and risk of loss pass to the buyer at this point. Please revise your
disclosure in the notes to the financia l statements to clarify why you recognize
revenue at the time of shipment for thes e transactions and why you believe this
accounting policy is in acco rdance with SAB 104.
********
You may contact Claire Erlanger at (202) 551-3301 if you have questions
regarding comments on the financia l statements and related matte rs. Please contact me at
(202) 551-3813 with any other questions.
Sincerely,
Linda Cvrkel
Branch Chief