SEC Company Response from Nielsen Holdings plc (CIK 0001492633) — May 5, 2020
Nielsen Holdings plc (CIK 0001492633)
Date: May 5, 2020 · CIK: 0001492633 · Accession: 0001193125-20-133738
AI Filing Summary & Sentiment
File numbers found in text: 001-35042
Referenced dates: April 24, 2020
Letter
VIA EDGAR Division of Corporation Finance Office of Trade & Services Securities and Exchange Commission Re: Nielsen Holdings plc Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 27, 2020 File No. 001-35042
Dear Mr. Rhodes and Ms. Cvrkel:
Nielsen Holdings plc (the “Company”) is writing to respond to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated April 24, 2020, relating to the above-referenced document (the “Original Filing”). For your convenience, we have reproduced the Staff’s comment in bold immediately preceding the Company’s response.
Concurrently with the submission of this letter, the Company is filing, through the Commission’s Electronic Data Gathering, Analysis and Retrieval system, an amendment to the Original Filing (the “Amendment”) in response to the Staff’s comment.
Item 9A. Controls and Procedures
a) Evaluation of Disclosure Controls and Procedures, page 133
1. Please amend to provide an evaluation of the effectiveness of your disclosure controls and procedures as of the current fiscal year end, December 31, 2019, rather than December 31, 2018. Refer to Item 307 of Regulation S-K.
In response to the Staff’s comment, the Company has revised its disclosure in “Item 9A. Controls and Procedures” in the Amendment to clarify that the evaluation of the effectiveness of its disclosure controls and procedures was made as of December 31, 2019, rather than December 31, 2018.
If you have any additional questions or comments, please do not hesitate to contact me at 203-563-2831.
Sincerely,
/s/ Christopher Taft
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CORRESP
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filename1.htm
SEC Response Letter
Christopher Taft
Senior Vice President
&
Corporate Controller
May 5, 2020
VIA EDGAR
Mr. Blaise Rhodes
Ms. Linda Cvrkel
Division of Corporation Finance
Office of Trade &
Services
Securities and Exchange Commission
100 F Street,
N.E.
Washington, D.C. 20549
Re:
Nielsen Holdings plc
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 27, 2020
File No. 001-35042
Dear Mr. Rhodes and Ms. Cvrkel:
Nielsen Holdings plc
(the “Company”) is writing to respond to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated April 24, 2020, relating to the above-referenced document
(the “Original Filing”). For your convenience, we have reproduced the Staff’s comment in bold immediately preceding the Company’s response.
Concurrently with the submission of this letter, the Company is filing, through the Commission’s Electronic Data Gathering, Analysis and Retrieval
system, an amendment to the Original Filing (the “Amendment”) in response to the Staff’s comment.
Item 9A. Controls and
Procedures
a) Evaluation of Disclosure Controls and Procedures, page 133
1.
Please amend to provide an evaluation of the effectiveness of your disclosure controls and procedures as of
the current fiscal year end, December 31, 2019, rather than December 31, 2018. Refer to Item 307 of Regulation S-K.
In response to the Staff’s comment, the Company has revised its disclosure in “Item 9A. Controls and Procedures” in the
Amendment to clarify that the evaluation of the effectiveness of its disclosure controls and procedures was made as of December 31, 2019, rather than December 31, 2018.
If you have any additional questions or comments, please do not hesitate to contact me at
203-563-2831.
Sincerely,
/s/ Christopher Taft
Christopher Taft
Nielsen
40 Danbury Road, Wilton, CT 06897
tel 203 563 2831
christopher.taft@nielsen.com
www.nielsen.com