Disclaimer
The SEC Filings on this page are provided by EDGAR (www.sec.gov), the Electronic Data Gathering, Analysis, and Retrieval System of the U.S. Securities and Exchange Commission (SEC). EDGAR performs automated collection, validation, indexing, acceptance, and forwarding of submissions by companies and others who are required by law to file forms with the SEC. The information here is provided for your convenience only. Comcast has no control over the information provided by EDGAR and cannot guarantee the sequence, accuracy, or completeness of any information or data displayed through EDGAR. Accordingly, Comcast does not accept any responsibility for the content or use of any information obtained through EDGAR.
Consult Your Tax Advisor
The information in this document represents our understanding of federal income tax laws and regulations, but does not constitute personal tax advice based on your specific situation. It does not purport to be complete or to describe the consequences that may apply to you given your particular taxes. You should consult your own tax advisor regarding the applicability of any state, local and foreign tax laws.
September 24, 2018
Brian L. Roberts
Chairman and Chief Executive Officer
Comcast Corporation
One Comcast Center
Philadelphia, PA 19103
Re: Comcast Corporation
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. 001-32871
Dear Mr. Roberts:
We have reviewed your filing 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
Note 3: Revenues
NBCUniversal Segments
Distribution, page 11
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
Comcast Corporation
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 11
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.
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 if you have questions
regarding
comments on the financial statements and related matters. Please contact Greg
Dundas,
Attorney-Advisor, at (202) 551-3436 or Larry Spirgel, Assistant Director, at
(202) 551-
3815 with any other questions.
Sincerely,
FirstName LastNameBrian L. Roberts
Division of
Corporation Finance
Comapany NameComcast Corporation
Office of
Telecommunications
September 24, 2018 Page 2
cc: Elizabeth Wideman
FirstName LastName