SEC Comment Letter for Match Group, Inc. (MTCH) (CIK 0000891103) (MTCH) — Jun 10, 2013
Match Group, Inc. (MTCH) (CIK 0000891103)
Date: June 10, 2013 · CIK: 0000891103 · Accession: 0000000000-13-031446
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-20570
Letter
June 10 , 2013 Via E -mail Jeffrey W. Kip Chief Executive Officer IAC/InterActiveCorp 555 West 18th Street New York, NY 10011
Re: IAC/InterActiveCorp Form 10-K for the Fiscal Year Ended December 31, 2012 Filed March 1, 2013 Response dated June 5, 2013 File No. 000-20570
Dear Mr. Kip:
We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, w e may have additional comments.
Item 8. Consolidated Financial Statements and Supplementary Data, page 41
Notes to Consolidated Financial Statements, page 48
Note 11 – Long -Term Debt, page 68
1. We reviewed your response to comment 14 in our l etter dated May 29, 2013. Please tell us whether the payment of dividends by you or your subsidiaries could cause non - compliance with a financial ratio test. If so, please tell us your consideration of this potential non -compliance when analyzing the dis closure requirements of Rule 4 -08(e)(1) and 4 -08(e)(3)(i) and (ii) of Regulation S -X and the need for the condensed financial information prescribed by Rule 12 -04 of Regulation S -X as required by Schedule I of Rule 5 -04 of Regulation S -X.
Jeffrey W. Kip IAC/InterActiveCorp June 10 , 2013 Page 2
We urge all p ersons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filings include, as applicable, the information the Securities Act of 1933, all applicable Securities Act rules, the Securities Exchange Act of 1934, and all applicable Exchange Act rules require . Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Adam Phippen at (202) 551 -3336 or William Thompson at (202) 551 - 3344 if you have questions regarding comments on the financial statements and related matters . Please contact Charles Lee at (202) 551 -3427 , Lilyanna Peyser at (202) 551 -3222 or me at (202) 551-3720 with any other questions.
Sincerely,
/s/ Lilyanna L. Peyser for
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June 10 , 2013 Via E -mail Jeffrey W. Kip Chief Executive Officer IAC/InterActiveCorp 555 West 18th Street New York, NY 10011 Re: IAC/InterActiveCorp Form 10-K for the Fiscal Year Ended December 31, 2012 Filed March 1, 2013 Response dated June 5, 2013 File No. 000-20570 Dear Mr. Kip: We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, w e may have additional comments. Item 8. Consolidated Financial Statements and Supplementary Data, page 41 Notes to Consolidated Financial Statements, page 48 Note 11 – Long -Term Debt, page 68 1. We reviewed your response to comment 14 in our l etter dated May 29, 2013. Please tell us whether the payment of dividends by you or your subsidiaries could cause non - compliance with a financial ratio test. If so, please tell us your consideration of this potential non -compliance when analyzing the dis closure requirements of Rule 4 -08(e)(1) and 4 -08(e)(3)(i) and (ii) of Regulation S -X and the need for the condensed financial information prescribed by Rule 12 -04 of Regulation S -X as required by Schedule I of Rule 5 -04 of Regulation S -X. Jeffrey W. Kip IAC/InterActiveCorp June 10 , 2013 Page 2 We urge all p ersons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filings include, as applicable, the information the Securities Act of 1933, all applicable Securities Act rules, the Securities Exchange Act of 1934, and all applicable Exchange Act rules require . Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. You may contact Adam Phippen at (202) 551 -3336 or William Thompson at (202) 551 - 3344 if you have questions regarding comments on the financial statements and related matters . Please contact Charles Lee at (202) 551 -3427 , Lilyanna Peyser at (202) 551 -3222 or me at (202) 551-3720 with any other questions. Sincerely, /s/ Lilyanna L. Peyser for Mara L. Ransom Assistant Director cc: Joanne Hawkins IAC/InterActiveCorp Kathryn Gettles -Atwa Wachtell, Lipton, Rosen & Katz