SEC Comment Letter for iQIYI, (IQ) — Mar 13, 2018
iQIYI, Inc.
Date: March 13, 2018 · CIK: 0001722608 · Accession: 0000000000-18-007742
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 March 13 , 2018 Dr. Yu Gong Chief Executive Officer iQIYI, Inc. 9/F, iQIYI Innovation Building No. 2 Haidian North First Street Haidian District, Beijing 100080 People’s Republic of China
Re: iQIYI, Inc. Registration Statement on Form F-1 Filed February 27, 2018 File No. 333 -223263
Dear Dr. Gong :
We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Po licies
Recent Accounting Pronouncements, page F -37
1. You state that you have preliminarily assessed the impact the new revenue recognition guidance in Topic 606 will have on your consolidated financial statements including but not limited to presentation o f sales tax. Please revise to provide a qualitative discussion of the potential impact that this standard will have on your financial statements when adopted, specifically any impact expected to your primary sources of revenue, if applicable. In this reg ard, include a description of the effects of the standard that you
Dr. Yu Gong iQIYI, Inc. March 13 , 2018 Page 2
expect to apply and a comparison to your current revenue recognition policies. Describe the status of your process to implement the new standard and the significant implementation matters yet to be addressed. In addition, to the extent that you determine the quantitative impact that adoption of Topic 606 will have on your results, please also disclose such amounts.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prio r to the requested effective date of the registration statement.
You may contact Abe Friedman at (202) 551 -8298 or Theresa Brillant at (202) 551 -3307 if you have questions regarding comments on the financial statements and related matters. Please contact J. Nolan McWilliams, Attorney -Advisor , at (202) 551 -3217 or me at (202) 551 - 3469 with any other questions.
Sincerely,
/s/ Justin Dobbie
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Mail Stop 3561 March 13 , 2018 Dr. Yu Gong Chief Executive Officer iQIYI, Inc. 9/F, iQIYI Innovation Building No. 2 Haidian North First Street Haidian District, Beijing 100080 People’s Republic of China Re: iQIYI, Inc. Registration Statement on Form F-1 Filed February 27, 2018 File No. 333 -223263 Dear Dr. Gong : We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Notes to Consolidated Financial Statements 2. Summary of Significant Accounting Po licies Recent Accounting Pronouncements, page F -37 1. You state that you have preliminarily assessed the impact the new revenue recognition guidance in Topic 606 will have on your consolidated financial statements including but not limited to presentation o f sales tax. Please revise to provide a qualitative discussion of the potential impact that this standard will have on your financial statements when adopted, specifically any impact expected to your primary sources of revenue, if applicable. In this reg ard, include a description of the effects of the standard that you Dr. Yu Gong iQIYI, Inc. March 13 , 2018 Page 2 expect to apply and a comparison to your current revenue recognition policies. Describe the status of your process to implement the new standard and the significant implementation matters yet to be addressed. In addition, to the extent that you determine the quantitative impact that adoption of Topic 606 will have on your results, please also disclose such amounts. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prio r to the requested effective date of the registration statement. You may contact Abe Friedman at (202) 551 -8298 or Theresa Brillant at (202) 551 -3307 if you have questions regarding comments on the financial statements and related matters. Please contact J. Nolan McWilliams, Attorney -Advisor , at (202) 551 -3217 or me at (202) 551 - 3469 with any other questions. Sincerely, /s/ Justin Dobbie Justin Dobbie Legal Branch Chief Office of Transportation and Leisure cc: Z. Julie Gao, Esq. Skadden, Arps, Slate, Meagher & Flom LLP