SEC Comment Letter for Match Group, Inc. (MTCH) (CIK 0000891103) (MTCH) — Nov 7, 2011
Match Group, Inc. (MTCH) (CIK 0000891103)
Date: Nov. 7, 2011 · CIK: 0000891103 · Accession: 0000000000-11-064735
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-20570
Referenced dates: September 7, 2011
Letter
November 7, 2011 Via E-mail Gregory R. Blatt Chief Executive Officer IAC/InterActiveCorp 555 West 18th Street New York, NY 10011 Re: IAC/InterActiveCorp Form 10-K for Fiscal Year Ended December 31, 2010 Filed March 1, 2011 Definitive Proxy Statement on Schedule 14A Filed April 29, 2011 Response dated October 4, 2011 File No. 000-20570
Dear Mr. Blatt: We have reviewed your letter dated Oct ober 4, 2011 in response to our comment letter dated September 7, 2011 and have the follo wing comment. In some of our comments, we may ask you to provide us with informati on so we may better understand your disclosure. Please respond to this letter within te n business days by amending your filings, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your f acts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your f ilings and the information you provide in response to these comments, we may have additional comments. Definitive Proxy Statement on Schedule 14A
Compensation Discussion and Analysis, page 19
2010 Bonuses, page 21
1. We note your response to comments 4 and 6 in our letter dated September 7, 2011. Please disclose the following:
Disclose the actual EBITA and share pri ce performance measures achieved and explain how those performance measures grew by at least 5%. Describe how EBITA was cal culated, whether this measure was adjusted and, if so, explain how the adjustments were calculated.
Mr. Gregory R. Blatt IAC/InterActiveCorp November 7, 2011 Page 2
For each named executive officer, describe in greater detail the specific individual contributions and contextualize those ach ievements for purposes of demonstrating how they resulted in specific compensa tion decisions. We note your reference to Exhibit B of your response letter; however, this exhibit was not submitted as part of your correspondence. Please also confirm that you will include the information in the first two paragraphs of your response letter in future filings . Please see Item 402(b)(1)(v), Item 402(b)(2)(vi), (vii) and (ix), and Instructi on 5 to Item 402(b) of Regulation S-K.
Please contact Angie Kim, Staff Attorn ey, at (202) 551-3535, Brigitte Lippmann, Special Counsel, at (202) 551-3713 or me at (202) 551-3720 with any other questions.
Sincerely,
/s/ Brigitte Lippmann for
Mara L. Ransom Assistant Director
cc: Gregg Winiarski, General Counsel
Show Raw Text
November 7, 2011 Via E-mail Gregory R. Blatt Chief Executive Officer IAC/InterActiveCorp 555 West 18th Street New York, NY 10011 Re: IAC/InterActiveCorp Form 10-K for Fiscal Year Ended December 31, 2010 Filed March 1, 2011 Definitive Proxy Statement on Schedule 14A Filed April 29, 2011 Response dated October 4, 2011 File No. 000-20570 Dear Mr. Blatt: We have reviewed your letter dated Oct ober 4, 2011 in response to our comment letter dated September 7, 2011 and have the follo wing comment. In some of our comments, we may ask you to provide us with informati on so we may better understand your disclosure. Please respond to this letter within te n business days by amending your filings, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your f acts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your f ilings and the information you provide in response to these comments, we may have additional comments. Definitive Proxy Statement on Schedule 14A Compensation Discussion and Analysis, page 19 2010 Bonuses, page 21 1. We note your response to comments 4 and 6 in our letter dated September 7, 2011. Please disclose the following: Disclose the actual EBITA and share pri ce performance measures achieved and explain how those performance measures grew by at least 5%. Describe how EBITA was cal culated, whether this measure was adjusted and, if so, explain how the adjustments were calculated. Mr. Gregory R. Blatt IAC/InterActiveCorp November 7, 2011 Page 2 For each named executive officer, describe in greater detail the specific individual contributions and contextualize those ach ievements for purposes of demonstrating how they resulted in specific compensa tion decisions. We note your reference to Exhibit B of your response letter; however, this exhibit was not submitted as part of your correspondence. Please also confirm that you will include the information in the first two paragraphs of your response letter in future filings . Please see Item 402(b)(1)(v), Item 402(b)(2)(vi), (vii) and (ix), and Instructi on 5 to Item 402(b) of Regulation S-K. Please contact Angie Kim, Staff Attorn ey, at (202) 551-3535, Brigitte Lippmann, Special Counsel, at (202) 551-3713 or me at (202) 551-3720 with any other questions. Sincerely, /s/ Brigitte Lippmann for Mara L. Ransom Assistant Director cc: Gregg Winiarski, General Counsel