SEC Comment Letter for AMC Networks Inc. (AMCX) (CIK 0001514991) (AMCX) — May 24, 2017
AMC Networks Inc. (AMCX) (CIK 0001514991)
Date: May 24, 2017 · CIK: 0001514991 · Accession: 0000000000-17-018247
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35106
Letter
Mail Stop 3720 May 24, 2017 Sean S. Sullivan Chief Financial Officer AMC Networks, Inc. 11 Penn Plaza New York, New York 10001
Re: AMC Networks, Inc. Form 10 -K for Fiscal Year Ended December 31, 201 6 Filed February 24, 2017 File No. 001-35106
Dear Mr. Sullivan :
We have reviewed your filing and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
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 believe our comment appl ies to your facts and circumstances , please tell us why in your response.
After reviewing your response to th is comment, we may have additional comments.
Form 8-K filed May 4, 2017 1. We note your presentation of the non GAAP measure “LTM Adjusted Operating Income,” which you define as, reported Adjusted Operating Income for the trailing twelve months. In your next earning release, please revise your presentation to provide the disclosures required by Item 10 (e) (1)(i) of Regulation S -K, including a reconciliation of GAAP operating income for the trailing twelve months to LTM Adjusted Operating income.
Sean S. Sullivan AMC Networks, Inc. May 24, 2017 Page 2
We remind you that the company and its management are res ponsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Ivette Leon, Assistant Chief Accountant at 202-551-3351 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer, Staff Attorney at 202- 551-3451 or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Carlos Pacho for
Show Raw Text
Mail Stop 3720 May 24, 2017 Sean S. Sullivan Chief Financial Officer AMC Networks, Inc. 11 Penn Plaza New York, New York 10001 Re: AMC Networks, Inc. Form 10 -K for Fiscal Year Ended December 31, 201 6 Filed February 24, 2017 File No. 001-35106 Dear Mr. Sullivan : We have reviewed your filing and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. 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 believe our comment appl ies to your facts and circumstances , please tell us why in your response. After reviewing your response to th is comment, we may have additional comments. Form 8-K filed May 4, 2017 1. We note your presentation of the non GAAP measure “LTM Adjusted Operating Income,” which you define as, reported Adjusted Operating Income for the trailing twelve months. In your next earning release, please revise your presentation to provide the disclosures required by Item 10 (e) (1)(i) of Regulation S -K, including a reconciliation of GAAP operating income for the trailing twelve months to LTM Adjusted Operating income. Sean S. Sullivan AMC Networks, Inc. May 24, 2017 Page 2 We remind you that the company and its management are res ponsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Ivette Leon, Assistant Chief Accountant at 202-551-3351 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer, Staff Attorney at 202- 551-3451 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Carlos Pacho for Larry Spirgel Assistant Director AD Office 11 – Telecommunications