555 Eleventh Street, N.W., Suite 1000 Washington, D.C. 20004-1304 Tel: +1.202.637.2200 Fax: +1.202.637.2201 www.lw.com | ||||||
 | FIRM / AFFILIATE OFFICES | |||||
| Austin | Milan | |||||
| Beijing | Munich | |||||
| Boston | New York | |||||
| Brussels | Orange County | |||||
| July 28, 2022 | Century City | Paris | ||||
| Chicago | Riyadh | |||||
| Dubai | San Diego | |||||
| Düsseldorf | San Francisco | |||||
| Frankfurt | Seoul | |||||
| VIA EDGAR TRANSMISSION | Hamburg | Shanghai | ||||
| Hong Kong | Silicon Valley | |||||
| Division of Corporation Finance | Houston | Singapore | ||||
| Office of Technology | London | Tel Aviv | ||||
| U.S. Securities and Exchange Commission | Los Angeles | Tokyo | ||||
| 100 F Street, N.E. | Madrid | Washington, D.C. | ||||
| Washington, DC 20549 | ||||||
| Attention: Inessa Kessman and Robert Littlepage | ||||||
| Re: | Beasley Broadcast Group, Inc. |
Form 8-K filed May 9, 2022
Response filed July 15, 2022
File No. 000-29253
Dear Ms. Kessman and Mr. Littlepage:
On behalf of our client, Beasley Broadcast Group, Inc. (the “Company”), this letter is in response to the letter dated July 26, 2022, from the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”), relating to the above-referenced Current Report on Form 8-K and the Company’s response on July 15, 2022, to the Staff’s letter dated June 16, 2022.
The Staff’s comment is set forth below in bold, followed by the Company’s response to the comment.
Form 8-K filed May 9, 2022
Exhibit 99.1, page 6
| 1. | We note your response to comment two. Please confirm that in your reconciliations of Free Cash Flow, you will begin with the most comparable GAAP measure, net cash provided by (used in) operating activities. |
To the extent the Company uses a non-GAAP measure called free cash flow in future filings, the Company confirms that its reconciliations of free cash flow will begin with the most directly comparable GAAP financial measure, net cash provided by (used in) operating activities.
* * * * * *
July 28, 2022
Page 2
Please contact me at (202) 637-2332 if you have any questions regarding this matter.
| Sincerely, |
/s/ Brian D. Miller |
| Brian D. Miller |
| of LATHAM & WATKINS LLP |
| cc: | Caroline Beasley, Chief Executive Officer |
Marie Tedesco, Chief Financial Officer
Chris Ornelas, Executive Vice President and General Counsel
2