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United States securities and exchange commission logo
July 21, 2020
Daniel Murdock
Executive VP, Chief Accounting Officer & Controller
Comcast Corporation
One Comcast Center
Philadelphia, PA 19103-2838
Re: Comcast Corporation
Form 10-K for the
Year Ended December 31, 2019
Filed January 30,
2020
Form 10-Q for the
Quarter Ended March 31, 2020
Filed April 30,
2020
File No. 001-32871
Dear Mr. Murdock:
We have reviewed your filing 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 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.
Form 10-Q for the Quarter Ended March 31, 2020
Guarantee Structure, page 32
1. We note that you have
chosen to voluntarily comply with the amendments contained in
SEC Release No.
33-10762, Financial Disclosures about Guarantors and Issuers of
Guaranteed Securities
and Affiliates Whose Securities Collateralize a Registrant s
Securities, in
advance of the effective date of the amendments. Please tell us how you
considered the
requirement to disclose summarized financial information of each issuer
and guarantor of each
guaranteed security as specified in Rule 13-01(a)(4) of Regulation
S-X. Additionally,
revise your disclosure of the Guarantors notes payable to and
receivables from other
Comcast subsidiaries as of March 31, 2020 to also disclose such
amounts as of December
31, 2019 as required by Rule 13-01(a)(4)(v), and clarify whether
those amounts, or any
other amounts disclosed pursuant to Rule 13-01(a)(4), represent
current or non-current
assets and liabilities.
Daniel Murdock
Comcast Corporation
July 21, 2020
Page 2
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 Joyce Sweeney, Senior Staff Accountant at (202) 551-3449
or Kathleen
Collins, Accounting Branch Chief at (202) 551-3499 if you have any questions.
FirstName LastNameDaniel Murdock Sincerely,
Comapany NameComcast Corporation
Division of
Corporation Finance
July 21, 2020 Page 2 Office of Technology
FirstName LastName