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
AI Filing Summary & Sentiment
Reasoning
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
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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