SEC Company Response from Sphere Entertainment (SPHR) — Mar 18, 2020
Sphere Entertainment Co.
Date: March 18, 2020 · CIK: 0001795250 · Accession: 0001193125-20-076865
AI Filing Summary & Sentiment
File numbers found in text: 001-39245
Referenced dates: March 13, 2020
Letter
Office of Trade & Services Division of Corporation Finance Securities and Exchange Commission Re: MSG Entertainment Spinco, Inc. Registration Statement on Form 10 Filed on March 6, 2020 File No. 001-39245
Dear Mr. Dobbie:
This letter responds to the comment letter from the Staff of the Securities and Exchange Commission (the “Commission”), dated March 13, 2020, regarding the Registration Statement on Form 10 (the “Form 10”) of MSG Entertainment Spinco, Inc. (the “Company”) filed by the Company on March 6, 2020. The Company’s response to the comment letter follows.
The Company has filed today with Amendment No. 1 to the Form 10 all exhibits that were not included the initial Form 10 filed on March 6, 2020, but also respectfully notes that a form of each of the exhibits filed today (other than Exhibits 10.47, 10.48, 10.51, 10.52 and 10.53) was previously submitted with one of the Company’s Draft Registration Statements on Form 10.
Registration Statement on Form 10-12B
General
1. Please revise your exhibit index notes to indicate that portions of the Exhibits 10.4, 10.5, 10.18, 10.19, 10.21, and 10.23 through 10.26 have been omitted. Refer to Item 601(b)(10) of Regulation S-K.
Company Response: In response to the Staff’s comment, the Company has revised the exhibit list notes to the Form 10 to indicate that portions of the Exhibits 10.4, 10.5, 10.18, 10.19, 10.21, and 10.23 through 10.26 have been omitted.
* * * * * *
Should any member of the Staff have any questions or comments with respect to the enclosed materials, please do not hesitate to contact Robert W. Downes at (212) 558-4312.
Sincerely,
/s/ Philip D’Ambrosio
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CORRESP 1 filename1.htm CORRESP March 18, 2020 Justin Dobbie Legal Branch Chief Office of Trade & Services Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-9303 Re: MSG Entertainment Spinco, Inc. Registration Statement on Form 10 Filed on March 6, 2020 File No. 001-39245 Dear Mr. Dobbie: This letter responds to the comment letter from the Staff of the Securities and Exchange Commission (the “Commission”), dated March 13, 2020, regarding the Registration Statement on Form 10 (the “Form 10”) of MSG Entertainment Spinco, Inc. (the “Company”) filed by the Company on March 6, 2020. The Company’s response to the comment letter follows. The Company has filed today with Amendment No. 1 to the Form 10 all exhibits that were not included the initial Form 10 filed on March 6, 2020, but also respectfully notes that a form of each of the exhibits filed today (other than Exhibits 10.47, 10.48, 10.51, 10.52 and 10.53) was previously submitted with one of the Company’s Draft Registration Statements on Form 10. Registration Statement on Form 10-12B General 1. Please revise your exhibit index notes to indicate that portions of the Exhibits 10.4, 10.5, 10.18, 10.19, 10.21, and 10.23 through 10.26 have been omitted. Refer to Item 601(b)(10) of Regulation S-K. Company Response: In response to the Staff’s comment, the Company has revised the exhibit list notes to the Form 10 to indicate that portions of the Exhibits 10.4, 10.5, 10.18, 10.19, 10.21, and 10.23 through 10.26 have been omitted. * * * * * * Should any member of the Staff have any questions or comments with respect to the enclosed materials, please do not hesitate to contact Robert W. Downes at (212) 558-4312. Sincerely, /s/ Philip D’Ambrosio Philip D’Ambrosio Interim Chief Financial Officer, Treasurer and Secretary cc: Robert W. Downes, Esq., Sullivan & Cromwell LLP Robert P. Nardone, KMPG LLP Tonya K. Aldave, Securities and Exchange Commission Lyn Shenk, Securities and Exchange Commission Scott Stringer, Securities and Exchange Commission