Correspondence 0000929351-23-000021 from STARZ ENTERTAINMENT CORP /CN/ (STRZ)
STARZ ENTERTAINMENT CORP /CN/
Date: May 31, 2023 · CIK: 0000929351 · Accession: 0000929351-23-000021
AI Filing Summary & Sentiment
File numbers found in text: 001-14880
Referenced dates: February 9, 2023, May 23, 2023, May 25, 2023
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CORRESP 1 filename1.htm Document May 31, 2023 Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Suying Li and Rufus Decker Division of Corporation Finance Office of Trade & Services Re: Lions Gate Entertainment Corp. Form 10-K for the Fiscal Year Ended March 31, 2022 Filed May 26, 2022 Item 2.02 Form 8-K dated February 9, 2023 File No. 001-14880 Ladies and Gentlemen: We respectfully submit below the responses of Lions Gate Entertainment Corp., a British Columbia, Canada corporation (“Lions Gate,” “Lionsgate,” “the Company,” “we,” “us,” or “our”), to the comments of the United States Securities and Exchange Commission staff (the “Staff”) regarding our Current Report on Form 8-K dated February 9, 2023 contained in your letter dated May 23, 2023. For your convenience, we have included your original comments, each immediately followed by Lions Gate’s response. Item 2.02 Form 8-K dated February 9, 2023 Exhibit 99.1 Reconciliation of Net Income (Loss) Attributable to Lions Gate Entertainment Corp. Shareholders..., page 18 Comment 1: We read your response to comment 2 and continue to believe that your non-GAAP adjustment to remove the effects of the deferred tax asset valuation allowance results in individually-tailored accounting. Please remove this adjustment from Adjusted Net Income (Loss) Attributable to Lions Gate Entertainment Corp. Shareholders. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Response: In response to the Staff's comment, we have removed the non-GAAP adjustment to remove the effects of the deferred tax asset valuation allowance from our calculation of Adjusted Net Income (Loss) Attributable to Lions Gate Entertainment Corp. Shareholders in our Current Report on Form 8-K dated May 25, 2023, and will exclude the adjustment for the effects of the deferred tax asset valuation allowance in future filings. ***** We hope that this letter has been helpful and responsive to your requests. If you have any questions or comments to these responses, please contact me directly at 310-255-5159. Sincerely, /s/ James W. Barge James W. Barge Chief Financial Officer