SEC Comment Letter for ZIFF DAVIS, INC. (ZD) (CIK 0001084048) (ZD) — Sep 7, 2016
ZIFF DAVIS, INC. (ZD) (CIK 0001084048)
Date: Sept. 7, 2016 · CIK: 0001084048 · Accession: 0000000000-16-091799
AI Filing Summary & Sentiment
Letter
Mail Stop 3720 September 7 , 2016 Nehemia Zucker Chief Executive Officer J2 Global , Inc. 6922 Hollywood Boulevard, Suite 500 Los Angeles, CA 90028
Re: J2 Global , Inc. Form 10 -K for Fiscal Year Ended December 31, 2015 Filed February 2 9, 2016 Form 8 -K filed August 4, 2016 File No. 0-25965
Dear Mr. Zucker :
We have limited our review of your filing s to the financial statements and related disclosures and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
Please respond to th is comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response.
After revie wing your response to the comment, we may have additional comments.
Form 8 -K filed August 4, 2016
Exhibit 99.1
1. Your presentation of a full non -GAAP income statement as a reconciliation of GAAP to non-GAAP financial measures is inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretation Guidance on non -GAAP financial measures issued on May 17, 2016. Please revise in your next earnings release.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are
Nehemia Zucker J2 Global , Inc. September 7 , 2016 Page 2
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.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceedin g initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Claire DeLabar, Staff Accountant at (202) 551 -3349 or Terry French, Accountant Branch Chief at (202) 551 -3828 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Terry French for
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Mail Stop 3720 September 7 , 2016 Nehemia Zucker Chief Executive Officer J2 Global , Inc. 6922 Hollywood Boulevard, Suite 500 Los Angeles, CA 90028 Re: J2 Global , Inc. Form 10 -K for Fiscal Year Ended December 31, 2015 Filed February 2 9, 2016 Form 8 -K filed August 4, 2016 File No. 0-25965 Dear Mr. Zucker : We have limited our review of your filing s to the financial statements and related disclosures and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. Please respond to th is comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response. After revie wing your response to the comment, we may have additional comments. Form 8 -K filed August 4, 2016 Exhibit 99.1 1. Your presentation of a full non -GAAP income statement as a reconciliation of GAAP to non-GAAP financial measures is inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretation Guidance on non -GAAP financial measures issued on May 17, 2016. Please revise in your next earnings release. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are Nehemia Zucker J2 Global , Inc. September 7 , 2016 Page 2 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. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceedin g initiated by the Commission or any person under the federal securities laws of the United States. You may contact Claire DeLabar, Staff Accountant at (202) 551 -3349 or Terry French, Accountant Branch Chief at (202) 551 -3828 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Terry French for Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications