United States securities and exchange commission logo
May 18, 2022
Lance Barton
Chief Financial Officer
PLBY Group, Inc.
10960 Wilshire Blvd.
Suite 2200
Los Angeles, CA 90024
Re: PLBY Group, Inc.
Form 10-K for the
Year Ended December 31, 2021
Filed March 16,
2022
Form 10-Q for the
Quarterly Period Ended March 31, 2022
Filed May 10, 2022
File No. 001-39312
Dear Mr. Barton:
We have limited our review of your filings to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply 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-K for the Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations
Comparison of Fiscal Years Ended December 31, 2021 and 2020, page 46
1. Where you attribute
material fluctuations in your revenues, costs, and expenses to
multiple factors,
please quantify each factor cited so that investors may understand the
magnitude and relative
impact of each factor. Refer to Item 303(b) of Regulation S-K.
Lance Barton
FirstName LastNameLance Barton
PLBY Group, Inc.
Comapany
May NamePLBY Group, Inc.
18, 2022
May 18,
Page 2 2022 Page 2
FirstName LastName
Item 8. Financial Statements and Supplementary Data, page 59
2. We note the Company ceased to be a smaller reporting company as of
December 31,
2021. Please amend your filing to include:
Management s discussion and analysis of financial condition and
results of
operations covering the three most recent annual periods in
accordance with
Item 303 of Regulation S-K, or disclose the location where any
omitted discussion
may be found in a prior EDGAR filing;
Three years of Statements of Operations, Cash Flows, and
Stockholders Equity, as
required under Rules 3-02 and 3-04 of Regulation S-X; and,
Auditor s report covering the three years presented.
Form 10-Q for the Quarterly Period Ended March 31, 2022
Exhibits 32.1 and 32.2, page 1
3. We note your Section 906 certifications reference your "Form 10-Q for
the period ended
September 30, 2021." Please amend your Form 10-Q to provide updated
certifications
that reference the correct period.
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 Abe Friedman at
202-551-
8298 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services