IAC/INTERACTIVECORP
555 West 18th Street
New York, New York 10011
June 13, 2007
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Linda Cvrkel
RE: IAC/INTERACTIVECORP
Form 10-K for the year ended December 31, 2006
Filed March 1, 2007
File No. 000-20570
Dear Ms. Cvrkel:
Set forth below is the Staff’s comment conveyed in your comment letter dated June 8, 2007 pertaining to the filing listed above, along with the Company’s response:
Form 10-K for the year ended December 31, 2006
Notes to the Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page 77
1. We note from your response to our prior comment 1 that you recognize revenue for domestic electronic retailing transactions at the time of shipment because you believe that title and risk of loss pass to the buyer at this point. Please revise your disclosure in the notes to the financial statements to clarify why you recognize revenue at the time of shipment for these transactions and why you believe this accounting policy is in accordance with SAB 104.
Response:
The Staff’s comment is noted, and in future filings the Company will revise our disclosure in the notes to the financial statements to clarify why we recognize revenue at the time of shipment for domestic electronic retailing transactions and why we believe this accounting policy is in accordance with SAB 104.
Please contact me at 212-314-7260 (fax: 212-632-9690) if you would like to discuss this response.
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| Sincerely, | |
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| /s/ Thomas J. McInerney |
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| Thomas J. McInerney |
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| Executive Vice President and |
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| Chief Financial Officer |
Copy to: | Claire Erlanger |
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| SECURITIES AND EXCHANGE COMMISSION |
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| Gregory R. Blatt |
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| Executive Vice President, |
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| General Counsel and Secretary |
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