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SEC Comment Letter for Dolphin Entertainment, Inc. (DLPN) (CIK 0001282224) (DLPN) — Dec 19, 2017

Dolphin Entertainment, Inc. (DLPN) (CIK 0001282224)
Date: Dec. 19, 2017 · CIK: 0001282224 · Accession: 0000000000-17-044200

Financial Reporting Internal Controls Regulatory Compliance

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
December 18, 2017
Author
/s/ Larry Spirgel
Form
UPLOAD
Company
Dolphin Entertainment, Inc. (DLPN) (CIK 0001282224)

Letter

Mail Stop 3720 December 18, 2017 William O’Dowd, IV Chief Executive Officer Dolphin Entertainment, Inc. 2151 LeJeune Road, Suite 150 -Mezzanine Coral Gables, FL 33134

Re: Dolphin Entertainment, Inc. Amendment No. 3 to Re gistration Statement on Form S -1 Filed December 15, 2017 File No. 333 -219029

Dear Mr. O’Dowd :

We have reviewed your amended registration statement and have the following comment.

Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment applies 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 registration statement and the information you provide in response to this comment , we may have additional comments .

Note 14 – Variable Interest Entities, p age F -71

1. It appears based on your disclosure that most of yo ur operations stem from the consolidation of your VIE, Max Steel Productions LLC. As such, please expand your disclosure to include the disclosures required by ASC 810 -10-50-2AA(b) and (c). Also, in accordance with ASC 810 -10-50-2AA (d), disclose how you r involvement with your VIEs affects your cash flows.

William O’Dowd, IV Dolphin Entertainment, Inc. December 18, 2017 Page 2

You may contact Inessa Kessman, Senior Staff Accountant, at (202) 551 -3371 or Terry French, Accountant Branch Chief, at (202) 551 -3828 if you have questions regarding comments on the financial s tatements and related matters. Please contact Joshua Shainess, Attorney - Adviser, at (202) 551 -7951 or me at (202) 551 -3810 with any other questions.

Sincerely,
/s/ Larry Spirgel

Show Raw Text
Mail Stop 3720

December 18, 2017

William O’Dowd, IV
Chief Executive Officer
Dolphin Entertainment, Inc.
2151 LeJeune Road, Suite 150 -Mezzanine
Coral Gables, FL 33134

Re: Dolphin Entertainment, Inc.
Amendment No. 3  to Re gistration Statement on Form S -1
Filed December 15, 2017
  File No. 333 -219029

Dear Mr. O’Dowd :

We have reviewed your amended registration statement  and have the following comment.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comment applies  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 registration statement and the information you
provide in response to this comment , we may have  additional comments .

Note 14 – Variable Interest Entities, p age F -71

1. It appears based on your disclosure that most of yo ur operations stem from the
consolidation of your VIE, Max Steel Productions LLC.  As such, please expand your
disclosure to include the disclosures required by ASC 810 -10-50-2AA(b) and (c).  Also,
in accordance with ASC 810 -10-50-2AA (d), disclose how you r involvement with your
VIEs affects your cash flows.

William O’Dowd, IV
Dolphin Entertainment, Inc.
December 18, 2017
Page 2

 You may  contact Inessa Kessman, Senior Staff Accountant,  at (202) 551 -3371  or Terry
French, Accountant Branch Chief, at (202) 551 -3828  if you have questions regarding comments
on the financial s tatements and related matters.  Please contact Joshua Shainess, Attorney -
Adviser,  at (202) 551 -7951  or me at (202) 551 -3810  with any other questions.

Sincerely,

/s/ Larry Spirgel

Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications