SEC Comment Letter for PENN Entertainment, Inc. (PENN) (CIK 0000921738) (PENN) — Oct 25, 2010
PENN Entertainment, Inc. (PENN) (CIK 0000921738)
Date: Oct. 25, 2010 · CIK: 0000921738 · Accession: 0000000000-10-062871
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-24206
Letter
October 25, 2010
William J. Clifford Chief Financial Officer Penn National Gaming, Inc. 825 Berkshire Blvd., Suite 200 Wyomissing, Pennsylvania 19610 Re: Penn National Gaming, Inc. Form 10-K for Fiscal Year Ended December 31, 2009 Filed on February 26, 2010 File No. 000-24206 Dear Mr. Clifford: We have reviewed your response letter da ted October 7, 2010 and 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 10 business days by confirming that you will revise your document in future filings and providing an y requested information. If you do not believe our comments apply to your facts and circumst ances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2009
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies
Goodwill and other intangible assets, page 39
1. We note your response to our prior comment one. Please revise your disclosure in future filings to disclose the basis for your belie f that disclosing information regarding the percentage by which fair value exceeded the ca rrying value as of the most recent step one of the impairment test for reporting units th at are at risk of failing step one of the impairment test will not provide meaningful information and that this information could be potentially misleading similar to the language provided in your response letter. Additionally, please revise to disclose your stat ement that you believe that at this time all of your reporting units are at risk of goodw ill impairment charges in future periods
William J. Clifford Penn National Gaming, Inc. October 25, 2010 Page 2
regardless of the margin by which the current fair value of your reporting unit exceeds its carrying value and that such margin cannot and should not be relied upon to predict which properties are most at risk for future impairment charges. Please provide us with a copy of your intended revised disclosure.
You may contact Aamira Chaudhry at 202-551- 3389 for questions regarding the financial statements. You may also call me at 202-551-3380. Sincerely,
Lyn Shenk Branch Chief
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October 25, 2010
William J. Clifford Chief Financial Officer Penn National Gaming, Inc. 825 Berkshire Blvd., Suite 200 Wyomissing, Pennsylvania 19610
Re: Penn National Gaming, Inc.
Form 10-K for Fiscal Year Ended December 31, 2009
Filed on February 26, 2010
File No. 000-24206
Dear Mr. Clifford:
We have reviewed your response letter da ted October 7, 2010 and 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 10 business days by confirming that you will revise
your document in future filings and providing an y requested information. If you do not believe
our comments apply to your facts and circumst ances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2009
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies
Goodwill and other intangible assets, page 39
1. We note your response to our prior comment one. Please revise your disclosure in future
filings to disclose the basis for your belie f that disclosing information regarding the
percentage by which fair value exceeded the ca rrying value as of the most recent step one
of the impairment test for reporting units th at are at risk of failing step one of the
impairment test will not provide meaningful information and that this information could
be potentially misleading similar to the language provided in your response letter.
Additionally, please revise to disclose your stat ement that you believe that at this time all
of your reporting units are at risk of goodw ill impairment charges in future periods
William J. Clifford Penn National Gaming, Inc. October 25, 2010 Page 2
regardless of the margin by which the current fair value of your reporting unit exceeds its
carrying value and that such margin cannot and should not be relied upon to predict
which properties are most at risk for future impairment charges. Please provide us with a
copy of your intended revised disclosure.
You may contact Aamira Chaudhry at 202-551- 3389 for questions regarding the financial
statements. You may also call me at 202-551-3380.
Sincerely,
Lyn Shenk Branch Chief