SEC Comment Letter for Live Nation Entertainment, Inc. (LYV) (CIK 0001335258) (LYV) — May 1, 2017
Live Nation Entertainment, Inc. (LYV) (CIK 0001335258)
Date: May 1, 2017 · CIK: 0001335258 · Accession: 0000000000-17-015116
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 May 1, 2017 Kathy Willard Chief Financial Officer Live Nation Entertainment, Inc. 9348 Civic Center Drive Beverly Hills, California 90210
Re: Live Nation Entertainment , Inc. Form 10-K for the Year Ended December 31, 2016 Form 8 -K furnished February 23 , 2017 File No. 001 -32601
Dear Ms. Willard :
We have reviewed your April 18, 2017 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not belie ve our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 8 -K furnished February 23, 2017
Exhibit 99.1
Reconciliation of Non -GAAP Measures to their Most Directly Comparable GAAP Measures (Unaudited), page 8
1. We note your response to prior comment 2. However, since free cash flow is typically calculated as cash flow from operations adjusted by capital expenditures and yo ur definition of free cash flow differs from the typical definition per Question 102.07 of the May 2016 C&DI on non -GAAP measures, we continue to believe you should retitle this measure to adjusted free cash flow or something similar. Please appropriately retitle the measure and advise.
Kathy Willard Live Nation Entertainment , Inc. May 1, 2017 Page 2
You may contact Heather Clark at 202 -551-3624 or Claire Erlanger at 202 -551-3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561 May 1, 2017 Kathy Willard Chief Financial Officer Live Nation Entertainment, Inc. 9348 Civic Center Drive Beverly Hills, California 90210 Re: Live Nation Entertainment , Inc. Form 10-K for the Year Ended December 31, 2016 Form 8 -K furnished February 23 , 2017 File No. 001 -32601 Dear Ms. Willard : We have reviewed your April 18, 2017 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not belie ve our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 8 -K furnished February 23, 2017 Exhibit 99.1 Reconciliation of Non -GAAP Measures to their Most Directly Comparable GAAP Measures (Unaudited), page 8 1. We note your response to prior comment 2. However, since free cash flow is typically calculated as cash flow from operations adjusted by capital expenditures and yo ur definition of free cash flow differs from the typical definition per Question 102.07 of the May 2016 C&DI on non -GAAP measures, we continue to believe you should retitle this measure to adjusted free cash flow or something similar. Please appropriately retitle the measure and advise. Kathy Willard Live Nation Entertainment , Inc. May 1, 2017 Page 2 You may contact Heather Clark at 202 -551-3624 or Claire Erlanger at 202 -551-3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3379 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure