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July 30, 2019
Via EDGAR Transmission
United States Securities and Exchange Commission
100 F Street N.E.
Washington D.C. 20549
Attention: Joseph Cascarano
Form10-K for Fiscal Year Ended December 31, 2018
Filed March 27, 2019
Form10-Q for the Fiscal Quarter Ended March 31, 2019
Filed May 14, 2019
File No. 001-38151
Ladies and Gentlemen:
We are providing this response letter with respect to the Staff’s comment letter dated July 23, 2019, regarding the above-referenced Form10-K for Fiscal Year Ended December 31, 2018 and Form10-Q for the Fiscal Quarter Ended March 31, 2018. For your convenience, the Staff’s comments have been reproduced below, followed by our response.
Form10-Q for Fiscal Quarters Ended March 31, 2019
Liquidity and Capital Resources
Selected Cash Flow Data, page 22
1. We note your presentation of aNon-GAAP measure called Adjusted studio operating cash flows, which we discussed on our call of June 5, 2019. Please revise future periodic filings and eliminate the measure as Adjusted studio operating cash flows violates Item 10(e)(1)(ii)(A) of RegulationS-K because it excludes charges or liabilities that required, or will require, cash settlement.
RESPONSE:
We acknowledge the Staff’s comment and will revise accordingly in future filings.
Please contact me at(424) 207-2132 if you have any questions.