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SEC Comment Letter for AMC Networks Inc. (AMCX) (CIK 0001514991) (AMCX) — Oct 25, 2018

AMC Networks Inc. (AMCX) (CIK 0001514991)
Date: Oct. 25, 2018 · CIK: 0001514991 · Accession: 0000000000-18-033391

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File numbers found in text: 001-35106

Date
October 22, 2018
Author
Sean Sullivan
Form
UPLOAD
Company
AMC Networks Inc. (AMCX) (CIK 0001514991)

Letter

October 22, 2018 Sean Sullivan Executive Vice President and Chief Financial Officer AMC Networks Inc. 11 Penn Plaza New York, NY 10001 Re:AMC Networks Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 1, 2018 Form 10-Q for the Quarterly Period Ended June 30, 2018 Filed August 2, 2018 File No. 001-35106 Dear Mr. Sullivan: We have reviewed your September 6, 2018 response to our comment letter 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. Please respond to these comments within ten business days by providing the requested information or advise 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 to these comments, we may have additional comments. Form 10-Q for the Quarterly Period Ended June 30, 2018 Content licensing revenue, page 7 1.We note your response to prior comment one. Please revise your disclosure to clarify that you consider each season of an episodic series to be a distinct unit of content and that you typically deliver all episodes of a season for a series concurrently. Reference ASC 606- 10-50-12.

Subscription fee revenue, page 7 2.We note your response to prior comment two. Please revise your disclosures to clarify

FirstName LastNameSean Sullivan Comapany NameAMC Networks Inc. October 22, 2018 Page 2 FirstName LastName Sean Sullivan AMC Networks Inc. October 22, 2018 Page 2 your determination that your programming is functional intellectual property. Reference 606-10-50-12. You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Carlos Pacho, Senior Assistant Chief Accountant at 202-551-3835 with any questions. Sincerely, Division of Corporation Finance Office of Telecommunications

Show Raw Text
October 22, 2018
Sean Sullivan
Executive Vice President and Chief Financial Officer
AMC Networks Inc.
11 Penn Plaza
New York, NY 10001
Re:AMC Networks Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 1, 2018
Form 10-Q for the Quarterly Period Ended June 30, 2018
Filed August 2, 2018
File No. 001-35106
Dear Mr. Sullivan:
            We have reviewed your September 6, 2018 response to our comment letter 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.
            Please respond to these comments within ten business days by providing the requested
information or advise 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 to these comments, we may have additional comments.
Form 10-Q for the Quarterly Period Ended June 30, 2018
Content licensing revenue, page 7
1.We note your response to prior comment one.  Please revise your disclosure to clarify that
you consider each season of an episodic series to be a distinct unit of content and that you
typically deliver all episodes of a season for a series concurrently.  Reference ASC 606-
10-50-12.

Subscription fee revenue, page 7
2.We note your response to prior comment two.  Please revise your disclosures to clarify

 FirstName LastNameSean Sullivan
 Comapany NameAMC Networks Inc.
 October 22, 2018 Page 2
 FirstName LastName
Sean Sullivan
AMC Networks Inc.
October 22, 2018
Page 2
your determination that your programming is functional intellectual property.  Reference
606-10-50-12.
            You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Carlos
Pacho, Senior Assistant Chief Accountant at 202-551-3835 with any questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications