SEC Comment Letter for Clear Channel Outdoor Holdings, Inc. (CCO) (CIK 0001334978) (CCO) — May 30, 2007
Clear Channel Outdoor Holdings, Inc. (CCO) (CIK 0001334978)
Date: May 30, 2007 · CIK: 0001334978 · Accession: 0000000000-07-026799
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 15, 2007, May 3, 2007
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 May 30, 2007 Mr. Randall T. Mays Chief Financial Officer Clear Channel Outdoor Holding, Inc. 200 East Basse Road San Antonio, Texas 78209 Re: Clear Channel Outdoor Holding, Inc. Form 10-K for Fiscal Year Ended December 31, 2006 Filed March 1, 2007 File No. 1-32663
Dear Mr. Mays: We have reviewed your supplemental response letter dated May 15, 2007 as well as your filing and have the following comments. As noted in our comment letter dated May 3, 2007, we have limited our review to only the issues addressed in our comments. Form 10-K for the fiscal year ended December 31, 2006
Item 8. Financial Statements and Supplementary Data
Note H – Commitments and Contingencies, page 68
1. We note your response to prior comment 3. In future filings, please disclose your accounting policy for rentals that include renewal options, annual rental escalation clauses, minimum franchise payments, and maintenance related to displays by providing the details included in your response.
2. We note you response to prior comment 4. In future filings, please expand upon your disclosures providing the details included in your response. Also tell us and disclose if there are any penalties or other consequences of not fulfilling these commitments and if you have currently or historically enc ountered any violations of these contracts.
* * * *
Mr. Randall T. Mays Clear Channel Outdoor Holding, Inc. May 30, 2007 Page 2 Please respond to these comments within 10 business days or tell us when you will provide us with a response. You may contact Michael Henderson, Staff Accountant, at (202) 551-3364 or Kyle Moffatt, Accountan t Branch Chief, at (202) 551-3836 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
S i n c e r e l y , L a r r y S p i r g e l A s s i s t a n t D i r e c t o r
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
May 30, 2007
Mr. Randall T. Mays Chief Financial Officer Clear Channel Outdoor Holding, Inc. 200 East Basse Road San Antonio, Texas 78209
Re: Clear Channel Outdoor Holding, Inc.
Form 10-K for Fiscal Year Ended December 31, 2006
Filed March 1, 2007 File No. 1-32663
Dear Mr. Mays:
We have reviewed your supplemental response letter dated May 15, 2007 as well
as your filing and have the following comments. As noted in our comment letter dated May 3, 2007, we have limited our review to only the issues addressed in our comments. Form 10-K for the fiscal year ended December 31, 2006
Item 8. Financial Statements and Supplementary Data
Note H – Commitments and Contingencies, page 68
1. We note your response to prior comment 3. In future filings, please disclose your
accounting policy for rentals that include renewal options, annual rental escalation clauses, minimum franchise payments, and maintenance related to displays by providing the details included in your response.
2. We note you response to prior comment 4. In future filings, please expand upon your
disclosures providing the details included in your response. Also tell us and disclose if there are any penalties or other consequences of not fulfilling these commitments and if you have currently or historically enc ountered any violations of these contracts.
* * * *
Mr. Randall T. Mays
Clear Channel Outdoor Holding, Inc. May 30, 2007 Page 2
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. You may contact Michael Henderson, Staff Accountant, at (202) 551-3364 or Kyle Moffatt, Accountan t Branch Chief, at (202) 551-3836 if you
have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
S i n c e r e l y , L a r r y S p i r g e l A s s i s t a n t D i r e c t o r