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November 5, 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 September 30, 2018
Filed October 25, 2018
File No. 001-36438
Dear Mr. Roberts:
We have reviewed your October 9, 2018 response to our comment letter
and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this comment, we may have additional
comments.
Unless we note otherwise, our reference to prior comment is to a comment in our
September 24,
2018 letter
Form 10-Q for the Fiscal Quarter Ended September 30, 2018
NBCUniversal Media, LLC Financial Statements
Note 3: Revenue
Distribution, page 61
1. We note your response to prior comment 1. Please revise your disclosures
in future
filings to clarify that you consider your distribution agreements to be
functional licenses
of intellectual property. Please refer to ASC 606-10-50-12.
Brian L. Roberts
NBCUniversal Media, LLC
November 5, 2018
Page 2
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
November 5, 2018 Page 2 Office of
Telecommunications
FirstName LastName