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SEC Comment Letter for AMC Networks Inc. (AMCX) (CIK 0001514991) (AMCX) — Jun 4, 2015

AMC Networks Inc. (AMCX) (CIK 0001514991)
Date: June 4, 2015 · CIK: 0001514991 · Accession: 0000000000-15-029959

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File numbers found in text: 001-35106

Date
June 4, 2015
Author
/s/ Terry French for
Form
UPLOAD
Company
AMC Networks Inc. (AMCX) (CIK 0001514991)

Letter

June 4, 2015 Sean S. Sullivan Chief Financial Officer AMC Networks, Inc. 11 Penn Plaza New York, NY 10001

Re: AMC Networks, Inc. Form 10 -K for Fiscal Year Ended December 31, 2014 Filed February 26, 2015 File No. 001-35106

Dear Mr. Sullivan :

We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to these comments 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 believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response t o these comments, we may have additional comments.

Cash Flow Discussion, page 49

Continuing Operations, page 50

1. Your discussion of net cash provided by operating activities does not appear to contribute substantively to an understanding of your historical cash flows. When preparing the discussion and analysis of operating cash flows, you should address material changes in the underlying drivers that affect these cash flows. Please revise your disclosures to include a discussion of the underl ying reasons for changes in working capital accounts that affect operating cash flows.

Sean S. Sullivan AMC Networks, Inc. June 4, 2015 Page 2

Note 3. Acquisitions, page F -15

BBC America, page F -15

2. We note that on October 23, 2014 you acquired 49.9% ownership in BBC America. Referring to your basis in t he accounting literature, tell us how you determined that you should consolidate this joint venture.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the informa tion the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the discl osures they have made.

In responding to our comments, please provide a written statement from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the fe deral securities laws of the United States.

You may contact Inessa Kessman , Senior Staff Accountant, at 202-551-3371 or Terry French , Accounting Branch Chief, at 202-551-3828 or me at (202) 551 -3810 with any questions.

Sincerely,
/s/ Terry French for

Show Raw Text
June 4, 2015

Sean S. Sullivan
Chief Financial  Officer
AMC Networks, Inc.
11 Penn Plaza
New York, NY  10001

Re: AMC Networks, Inc.
 Form 10 -K for Fiscal Year Ended December 31, 2014
Filed February 26, 2015
File No. 001-35106

Dear Mr. Sullivan :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comments.  Please comply with the following comments in
future  filings.  Confirm in writing that you will do so and explain to us how you intend to
comply.   In some of our comments, we may ask you to provide us with information so we may
better understand your disclosure.

Please respond to these comments  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 believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response t o these  comments, we may have  additional comments.

Cash Flow Discussion, page 49

Continuing Operations, page 50

1. Your discussion of net cash provided by operating activities does not appear to contribute
substantively to an understanding of your historical cash flows. When preparing the
discussion and analysis of operating cash flows, you should address material changes in
the underlying drivers that affect these cash flows. Please revise your  disclosures to
include a discussion of the underl ying reasons for changes in working capital accounts
that affect operating cash flows.

Sean S. Sullivan
AMC Networks, Inc.
June 4, 2015
Page 2

 Note 3. Acquisitions, page F -15

BBC America, page F -15

2. We note that on October 23, 2014 you acquired 49.9% ownership in BBC America.
Referring to your basis in t he accounting literature, tell us how you determined that you
should consolidate this joint venture.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the informa tion the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the discl osures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the fe deral securities laws of the United States.

You may contact Inessa Kessman , Senior Staff Accountant,  at 202-551-3371  or Terry
French , Accounting  Branch Chief,  at 202-551-3828  or me at (202) 551 -3810 with any questions.

Sincerely,

 /s/ Terry French for

 Carlos Pacho
Senior Assistant Chief Accountant