United States securities and exchange commission logo
March 2, 2021
Christine McCarthy
Senior Executive Vice President and Chief Financial Officer
The Walt Disney Company
500 South Buena Vista Street
Burbank, CA 91521
Re: The Walt Disney
Company
Form 10-K for
Fiscal Year Ended October 3, 2020
Filed November 25,
2020
Form 10-Q for
Fiscal Quarter Ended January 2, 2021
Filed February 11,
2021
File No. 001-38842
Dear Ms. McCarthy:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we may ask
you to provide us
with information so we may better understand your disclosure.
Please respond to the comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-Q for Fiscal Quarter Ended January 2, 2021
Other Matters
Accounting Policies and Estimates
Goodwill, Other Intangible Assets, Long-Lived Assets and Investments,
page 45
1. In regard to your
Disney Parks, Experiences and Products segment, we note the following:
(1) over the last three
fiscal quarters through January 2, 2021, revenues are significantly
less than those of the
corresponding prior year quarter and segment operating income is
negative in each of
those quarters, and (2) disclosures that (i) COVID-19 has most
significantly impacted
this segment; (ii) certain parks remain closed or are operating at
significantly reduced
capacity, and cruise ship sailings and guided tours have been
suspended; (iii)
impacts of COVID-19 on your businesses will continue for an unknown
length of time and you
expect COVID-19 to adversely impact your financial results at
Christine McCarthy
The Walt Disney Company
March 2, 2021
Page 2
least through fiscal 2021; and (iv) COVID-19 has adversely impacted
your net cash flows,
and projected cash flows you use to assess fair value of your
businesses and assets for
purposes of impairment testing are subject to greater uncertainty than
normal because of
COVID-19. It appears there is no discussion concerning impairment
associated with this
segment.
In view of the preceding, please explain to us your analysis of
impairment of
goodwill, other intangible assets and long-lived assets for this
segment pursuant to ASC
350-20-35, 350-30-35 and 360-10-35, as appropriate. In so doing, tell
us the reporting
units included in this segment and whether any have been aggregated
for purposes of
goodwill impairment testing. Additionally, explain to us the
uncertainty associated with
the projected cash flows for the total segment and reporting units
therein due to COVID-
19 and how this impacted your analysis. If projected cash flows have
been adversely
impacted, please tell us the extent and the impact on your analysis.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Robert Shapiro at 202-551-3273 or Doug Jones at
202-551-3309 with
any questions.
FirstName LastNameChristine McCarthy Sincerely,
Comapany NameThe Walt Disney Company
Division of
Corporation Finance
March 2, 2021 Page 2 Office of Trade &
Services
FirstName LastName