United States securities and exchange commission logo
November 17, 2022
James A. McCarthy
Chief Financial Officer
Wilhelmina International, Inc.
5420 Lyndon B Johnson Freeway, Box #25
Dallas, Texas 75240
Re: Wilhelmina
International, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Response dated
August 26, 2022
File No. 001-36589
Dear James A. McCarthy:
We have reviewed your August 26, 2022 response to our comment
letter and have the
following comment.
Please respond to this 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 this comment, we may have additional comments.
Response Dated August 26, 2022
General
1. We have reviewed your
accounting for the recognition of model commissions revenue
through arrangements
where your represented talent provides modeling and/or social
media influencer
services to clients pursuant to arrangements between you and the client
( direct bookings
) as it relates to principal versus agent considerations under ASC
606. Based on the
information you provided, we object to your conclusion that you are
the principal for
direct bookings and therefore also object to your recognition of
revenue related to
direct bookings on a gross basis. We would not object to a conclusion
whereby you are the
agent for direct bookings and recognize revenue on a net basis.
James A. McCarthy
FirstName
WilhelminaLastNameJames A. McCarthy
International, Inc.
Comapany 17,
November NameWilhelmina
2022 International, Inc.
November
Page 2 17, 2022 Page 2
FirstName LastName
You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380
if you
have any questions.
Sincerely,
Division of Corporation
Finance
Office of Trade &
Services