SEC Comment Letter for Match Group, Inc. (MTCH) (CIK 0000891103) (MTCH) — Jun 19, 2008
Match Group, Inc. (MTCH) (CIK 0000891103)
Date: June 19, 2008 · CIK: 0000891103 · Accession: 0000000000-08-030559
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 15, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-3561 DIVISION OF CORPORATION FINANCE VIA FACSIMILE AND U.S. MAIL June 19, 2008 Mr. Thomas J. McInerney Executive Vice President and Chief Financial Officer IAC/InterActiveCorp 555 West 18 th Street New York, New York 10011 Re: IAC/InterActiveCorp Form 10-K for Fiscal Ye ar Ended December 31, 2007 Filed February 29, 2008 Form 10-Q for Fiscal Quar ter Ended March 31, 2008 Filed May 7, 2008 File No. 0-20570
Dear Mr. McInerney: We have reviewed your response dated June 3, 2008 to our comment letter dated May 15, 2008 and have the following additiona l comment. Please provide a written response to our comment. Please be as deta iled as necessary in your explanation. We may ask you to provide us with information so that we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments. Form 10-K for Fiscal Year Ended December 31, 2007
Note 2 – Summary of Significan t Accounting Policies, page 86 Revenue Recognition, page 86 Ticketmaster, page 86 1. We reviewed your response to comment two in our letter dated May 15, 2008. In accordance with the guidance in Rule 5-03(b)(7) of Regulation S-X, please classify interest income as a component of non-operating income or explain to us in further detail why it is appropriate to cl assify interest income as revenue. Since such interest income is generated from the investment of funds and does not result from transactions with customers, pleas e clarify why revenue classification is appropriate and why you believe this intere st income is substantively different from the interest income you classify within non-operating income. Additionally, explain why you believe the segregation of funds collected on be half of customers
Mr. Thomas J. McInerney IAC/InterActiveCorp June 19, 2008 Page 2 of 2 impacts the classification of interest income received on such funds. In your response, please provide us with the am ount of interest income included in revenue for all periods presented.
* * * *
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a response letter that ke ys your response to our comment and provides any requested info rmation. Detailed response letters greatly facilitate our review. Please submit your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comment.
You may contact Sarah Goldberg, Assist ant Chief Accountant, at (202) 551-3340 or, in her absence, Robyn Manuel at (202) 551-3823 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3344 with any other questions. S i n c e r e l y , William Thompson B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561
DIVISION OF
CORPORATION FINANCE
VIA FACSIMILE AND U.S. MAIL
June 19, 2008
Mr. Thomas J. McInerney Executive Vice President and Chief Financial Officer IAC/InterActiveCorp 555 West 18
th Street
New York, New York 10011
Re: IAC/InterActiveCorp
Form 10-K for Fiscal Ye ar Ended December 31, 2007
Filed February 29, 2008
Form 10-Q for Fiscal Quar ter Ended March 31, 2008
Filed May 7, 2008
File No. 0-20570
Dear Mr. McInerney:
We have reviewed your response dated June 3, 2008 to our comment letter dated
May 15, 2008 and have the following additiona l comment. Please provide a written
response to our comment. Please be as deta iled as necessary in your explanation. We
may ask you to provide us with information so that we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional
comments. Form 10-K for Fiscal Year Ended December 31, 2007
Note 2 – Summary of Significan t Accounting Policies, page 86
Revenue Recognition, page 86
Ticketmaster, page 86
1. We reviewed your response to comment two in our letter dated May 15, 2008. In
accordance with the guidance in Rule 5-03(b)(7) of Regulation S-X, please
classify interest income as a component of non-operating income or explain to us
in further detail why it is appropriate to cl assify interest income as revenue. Since
such interest income is generated from the investment of funds and does not result
from transactions with customers, pleas e clarify why revenue classification is
appropriate and why you believe this intere st income is substantively different
from the interest income you classify within non-operating income. Additionally,
explain why you believe the segregation of funds collected on be half of customers
Mr. Thomas J. McInerney
IAC/InterActiveCorp June 19, 2008 Page 2 of 2
impacts the classification of interest income received on such funds. In your
response, please provide us with the am ount of interest income included in
revenue for all periods presented.
* * * *
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please furnish a response letter that ke ys your response to
our comment and provides any requested info rmation. Detailed response letters greatly
facilitate our review. Please submit your response letter on EDGAR. Please understand
that we may have additional comments after reviewing your responses to our comment.
You may contact Sarah Goldberg, Assist ant Chief Accountant, at (202) 551-3340
or, in her absence, Robyn Manuel at (202) 551-3823 if you have questions regarding
comments on the financial statements and related matters. Please contact me at (202) 551-3344 with any other questions. S i n c e r e l y ,
William Thompson
B r a n c h C h i e f