DIRECTV Holdings LLC
DIRECTV Financing Co., Inc.
2230 East Imperial Highway
El Segundo, CA 90245
April 19, 2006
VIA EDGAR
Mr. Larry Spirgel
Assistant Director
United States Securities and Exchange Commission
100 F. Street N.E.
Washington D.C. 20549-3561
Re: DIRECTV Holdings LLC and DIRECTV Financing Co., Inc.
Form 10-K for the year ended December 31, 2005 filed March 10, 2006
Commission file number: 333-106529
Dear Mr. Spirgel:
We have prepared the following response to address the comment contained in your letter dated April 3, 2006 regarding the above-referenced filing. As requested in your letter, we have prepared, where appropriate, proposed disclosure for future filings.
As requested in your letter, we acknowledge that:
• the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
• the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
For your convenience, our response corresponds to the format of your letter.
Form 10-K for the Fiscal Year Ended December 31, 2005
Consolidated Statements of Operations, page 41
1. Please revise your statements of operations to separately present cost and expenses applicable to net revenues in accordance with Rule 5-03 of Regulation S-X. In this regard, it appears from your statement that, at a minimum, your cost of revenues should include your broadcast programming and other costs of sale, broadcast operations expenses, and subscriber services expenses. With respect to your depreciation of property, plant and equipment and amortization of intangibles, please comply with SAB Topic 11:B.
Response
As requested, in future filings we will revise our statement of operations to separately present our costs and expenses as follows:
Operating Costs and Expenses |
Costs of revenues, exclusive of depreciation and amortization expense |
Broadcast programming and other |
Subscriber service expenses |
Broadcast operations expenses |
Selling, general and administrative expenses, exclusive of depreciation and amortization expense |
Subscriber acquisition costs |
Upgrade and retention costs |
General and administrative expenses |
Depreciation and amortization expense |
Total Operating Costs and Expenses |
We believe the above presentation is in accordance with Rule 5-03 of Regulation S-X and complies with SAB Topic 11:B.
* * * * * * *
We hope that this letter adequately addresses your comment. Please contact Pat Doyle, Senior Vice President, Treasurer at: (310) 964-0771 (phone), 310-964-0882 (fax), or patrick.doyle@directv.com (e-mail) should you have additional comments or require additional information.
Sincerely, | |
| |
/s/ Michael W. Palkovic |
|
Michael W. Palkovic | |
Executive Vice President and Chief Financial Officer | |
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