October 25, 2018
ViaE-mail and EDGAR:
Terry French
Accountant Branch Chief
Office of Telecommunications
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7010
| Re: | Tribune Media Company |
Form10-K for Fiscal Year Ended December 31, 2017 |
Form10-Q for Fiscal Quarter Ended June 30, 2018 |
FileNo. 001-08572 |
Dear Mr. French:
This letter sets forth the response of Tribune Media Company (the “Company” or “we”) to the comment contained in your letter, dated October 17, 2018, relating to the Company’s Annual Report on Form10-K for the fiscal year ended December 31, 2017, the Company’s Quarterly Report on Form10-Q for the fiscal quarter ended June 30, 2018 and the Company’s response, dated September 7, 2018, to the prior comment letter of the staff of the U.S. Securities and Exchange Commission (the “Staff”), dated August 23, 2018. The comment of the Staff is set forth in bold italicized text below, and the response of the Company is set forth in plain text immediately following. Please let us know if we can provide additional information to assist in the review process.
Form10-Q for Fiscal Quarter Ended June 30, 2018
Financial Statements
Note 1: Basis of Presentation and Significant Accounting Policies
Revenue Recognition, page 13
| 1. | We note your response to our comment letter dated August 23, 2018. Please revise your future filings to clarify that you recognize revenue on your advertising contracts with guarantees based on the proportion of audience member views delivered in relation to the total guaranteed audience member views in the contract. Please also revise to explain, as you do in your response, how you address scenarios where the guaranteed number of audience views is not achieved through the initial package of advertisements. Please refer to ASC606-10-50-12. |
In response to the Staff’s comment, the Company will revise its future filings as requested by the Staff, beginning with the Company’s Quarterly Report on Form10-Q for the quarterly period ended September 30, 2018.
* * * * *
Should you have any questions regarding this matter, please contact me at (312)222-5578 or cbigelow@tribunemedia.com or Brian Litman at (312)222-4237 or blitman@tribunemedia.com.
| /s/ Chandler Bigelow |
| Chandler Bigelow |
| Executive Vice President and Chief Financial Officer |
| Tribune Media Company |
| cc: | Clair DeLabar |
Securities and Exchange Commission
Larry Spirgel |
Securities and Exchange Commission
Brian Litman |
Tribune Media Company
