SEC Comment Letter for ZIFF DAVIS, INC. (ZD) (CIK 0001084048) (ZD) — Jun 3, 2013
ZIFF DAVIS, INC. (ZD) (CIK 0001084048)
Date: June 3, 2013 · CIK: 0001084048 · Accession: 0000000000-13-030100
AI Filing Summary & Sentiment
Letter
June 3 , 2013 Via E -mail Ms. Kathleen M. Griggs Chief Financial Officer j2 GLOBAL, INC. 6922 Hollywood Boulevard, Suite 500 Los Angeles, CA 90028
Re: j2 GLOBAL, INC. Form 10-K for the Year Ended December 31 , 2012 Filed March 1, 2013 File No. 0-25965
Dear Ms. Griggs :
We have reviewed your response letter and have the following comments. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. 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 providing the request ed 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, please tell us why in your response.
After reviewing the information you provide in response to the se comments, we may have additional comments.
Form 10 -K for the Year Ended December 31 , 201 2
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, pages 35 -39
1. We note your response to co mment three. It does not appear you complied with this comment in your most recent 10 -Q. Please advise.
2. We note your response to comment five and your ARPU disclosure on page 30 of your most recent Form 10 -Q. As previously requested, please discuss the usefulness of ARPU to your investors.
Ms. Kathleen M. Griggs j2 GLOBAL, INC. June 3 , 2013 Page 2
7. Goodwill and Intangible Assets, page 64
Intangible Assets Subject to Amortization, page 65
3. Regarding your response to comment eight, the basis for your conclusion that j2’s utilization of a straight -line amort ization methodology rather than an accelerated amortization methodology is immaterial, is unclear. Please advise us in detail, including an explanation of the accelerated amortization methodologies that j2 should be utilizing, tell us how they were deter mined, and provide us a quantified analysis of the impact of the difference in methodologies on all affected financial statement line items in 2011 - 2013.
Ziff Davis, Inc. Equity Incentive Plan, page 78
4. We note your response to comment nine. As previously requested, disclose the specific factors you considered in concluding that the put right is within your control.
* * * *
You may contact Dean Suehiro , Senior Staff Accountant, at (202) 551-3384 or Robert S. Littlepage , Accountant Branch Chief , at (202) 551 -3361 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer , Staff Attorney, at 202 -551-3415 or me at (202) 551 -3810 with a ny other questions.
Sincerely,
/s/ Robert S. Littlepage for
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June 3 , 2013 Via E -mail Ms. Kathleen M. Griggs Chief Financial Officer j2 GLOBAL, INC. 6922 Hollywood Boulevard, Suite 500 Los Angeles, CA 90028 Re: j2 GLOBAL, INC. Form 10-K for the Year Ended December 31 , 2012 Filed March 1, 2013 File No. 0-25965 Dear Ms. Griggs : We have reviewed your response letter and have the following comments. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. 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 providing the request ed 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, please tell us why in your response. After reviewing the information you provide in response to the se comments, we may have additional comments. Form 10 -K for the Year Ended December 31 , 201 2 Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, pages 35 -39 1. We note your response to co mment three. It does not appear you complied with this comment in your most recent 10 -Q. Please advise. 2. We note your response to comment five and your ARPU disclosure on page 30 of your most recent Form 10 -Q. As previously requested, please discuss the usefulness of ARPU to your investors. Ms. Kathleen M. Griggs j2 GLOBAL, INC. June 3 , 2013 Page 2 7. Goodwill and Intangible Assets, page 64 Intangible Assets Subject to Amortization, page 65 3. Regarding your response to comment eight, the basis for your conclusion that j2’s utilization of a straight -line amort ization methodology rather than an accelerated amortization methodology is immaterial, is unclear. Please advise us in detail, including an explanation of the accelerated amortization methodologies that j2 should be utilizing, tell us how they were deter mined, and provide us a quantified analysis of the impact of the difference in methodologies on all affected financial statement line items in 2011 - 2013. Ziff Davis, Inc. Equity Incentive Plan, page 78 4. We note your response to comment nine. As previously requested, disclose the specific factors you considered in concluding that the put right is within your control. * * * * You may contact Dean Suehiro , Senior Staff Accountant, at (202) 551-3384 or Robert S. Littlepage , Accountant Branch Chief , at (202) 551 -3361 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer , Staff Attorney, at 202 -551-3415 or me at (202) 551 -3810 with a ny other questions. Sincerely, /s/ Robert S. Littlepage for Larry Spirgel Assistant Director