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September 24, 2018
Brian L. Roberts
Chairman and Chief Executive Officer
NBCUniversal Media, LLC
30 Rockefeller Plaza
New York, NY 10112-0015
Re: NBCUniversal Media LLC
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed January 31, 2018
Form 10-Q for the Fiscal Quarter Ended June 30, 2018
Filed July 26, 2018
File No. 001-36438
Dear Mr. Roberts:
We have limited our review of your filing to the financial statements
and related
disclosures 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 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 Fiscal Quarter Ended June 30, 2018
NBCUniversal Media, LLC Financial Statements
Note 3: Revenue
Distribution, page 58
1. Please identify the specific products and/or services transferred to your
customers within
your distribution and affiliate agreements. Tell us if you have combined
any products
and/or services for purposes of determining your performance obligations.
Specifically
address if these arrangements contain a video-on-demand library. Tell us
if you believe
these arrangements contain a functional license of intellectual property
and if this is the
predominant item to which royalties relate. Please also describe the
judgements used in
Brian L. Roberts
NBCUniversal Media, LLC
September 24, 2018
Page 2
determining both the timing of satisfaction and amounts allocated to
each performance
obligation. Refer to ASC 606-10-50-12 and 606-10-50-17.
Content Licensing, page 59
2. Please tell us if content licensing agreements include promises to
provide content
libraries. If these arrangements are material, please tell us how you
considered if existing
content and new content represent separate performance obligations and
explain how you
considered judgments in determining both amounts allocated to and the
timing of
satisfaction of each performance obligation. Refer to ASC 606-10-50-12
and 606-10-50-
17.
3. For content licensing agreements that include variable pricing, you
disclose that you
recognize revenue as variable amounts become known. Please further
clarify your
statement and tell us how you consider amounts earned when there is a
lag in reporting.
Please refer to ASC 606-10-32-5 and 606-10-50-20.
In closing, 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.
You may contact Joseph Cascarano, Staff Accountant, at (202) 551-3376
or Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 with any questions.
FirstName LastNameBrian L. Roberts Sincerely,
Comapany NameNBCUniversal Media, LLC
Division of
Corporation Finance
September 24, 2018 Page 2 Office of
Telecommunications
FirstName LastName