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SEC Company Response from Warner Music Group Corp. (WMG) (CIK 0001319161) (WMG) — Feb 6, 2020

Warner Music Group Corp. (WMG) (CIK 0001319161)
Date: Feb. 6, 2020 · CIK: 0001319161 · Accession: 0001193125-20-026898

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
February 6, 2020
Author
/s/ Matthew E. Kaplan
Form
CORRESP
Company
Warner Music Group Corp. (WMG) (CIK 0001319161)

Letter

Division of Corporation Finance Office of Trade & Services Re: Warner Music Group Corp. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted November 27, 2019 CIK No. 0001319161

Dear Ms. Kaufman:

This letter sets forth the response of Warner Music Group Corp. (the “Registrant”) to the comment contained in your letter, dated December 9, 2019, relating to Amendment No. 2 to the Draft Registration Statement on Form S-1, confidentially submitted by the Registrant on November 27, 2019 (“Amendment No. 2”). The comment of the staff of the U.S. Securities and Exchange Commission (the “Staff”) is set forth in bold italicized text below, and the Registrant’s response is set forth in plain text immediately following the comment.

The Registrant is filing, via EDGAR, Amendment No. 3 to the Registration Statement (“Amendment No. 3”). Enclosed with the paper copy of this letter are two copies of a clean version of Amendment No. 3, as well as two copies of a blacklined version of Amendment No. 3, marked to show changes from Amendment No. 2.

Capitalized terms used but not defined herein have the meanings assigned to them in Amendment No. 3.

Amendment No. 2 to Draft Registration Statement on Form S-1

Consolidated Financial Statements

Report of Independent Registered Public Accounting Firm, page F-2

1. Please make arrangements with your auditors to revise their report to refer to the correct location where financial statement schedule II is listed.

The Registrant’s auditors have revised their report to refer to the correct location where financial statement schedule II is listed. Please see page F-2 of Amendment No. 3.

If you have any questions regarding this letter, please do not hesitate to call me at (212) 909-7334 or Eric T. Juergens at (212) 909-6301.

Best Regards,
/s/ Matthew E. Kaplan

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 February 6, 2020

Jacqueline Kaufman

 Staff Attorney

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Trade & Services

 100 F Street,
N.E.

 Washington, D.C. 20549-7010

Re:
 Warner Music Group Corp.

 Amendment No. 2 to Draft Registration Statement on Form S-1

 Submitted November 27, 2019

 CIK No. 0001319161

Dear Ms. Kaufman:

 This letter sets forth
the response of Warner Music Group Corp. (the “Registrant”) to the comment contained in your letter, dated December 9, 2019, relating to Amendment No. 2 to the Draft Registration Statement on Form S-1, confidentially
submitted by the Registrant on November 27, 2019 (“Amendment No. 2”). The comment of the staff of the U.S. Securities and Exchange Commission (the “Staff”) is set forth in bold italicized text below, and
the Registrant’s response is set forth in plain text immediately following the comment.

 The Registrant is filing, via EDGAR,
Amendment No. 3 to the Registration Statement (“Amendment No. 3”). Enclosed with the paper copy of this letter are two copies of a clean version of Amendment No. 3, as well as two copies of a blacklined version of
Amendment No. 3, marked to show changes from Amendment No. 2.

 Capitalized terms used but not defined herein have the meanings
assigned to them in Amendment No. 3.

 Amendment No. 2 to Draft Registration Statement on Form S-1

Consolidated Financial Statements

 Report of
Independent Registered Public Accounting Firm, page F-2

1.
 Please make arrangements with your auditors to revise their report to refer to the correct location where
financial statement schedule II is listed.

 The Registrant’s auditors have revised their report to refer to the correct
location where financial statement schedule II is listed. Please see page F-2 of Amendment No. 3.

 If you have any questions regarding this letter, please do not hesitate to call me at
(212) 909-7334 or Eric T. Juergens at (212) 909-6301.

 Best Regards,

/s/ Matthew E. Kaplan

Matthew E. Kaplan

cc:
 Jacqueline Kaufman

Mara Ransom

 Suying Li

Rufus Decker

 U.S. Securities and
Exchange Commission

 Paul Robinson

Trent Tappe

 Warner Music Group
Corp.

 Enclosures

 2