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November 7, 2018
Mr. Joseph Cascarano
Staff Accountant
Mr. Robert S. Littlepage
Accountant Branch Chief
Division of Corporation Finance
Office of Telecommunications
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| Re: | Comcast Corporation |
| Form 10-K for Fiscal Year Ended December 31, 2017 | |
| Filed January 31, 2018 | |
| Form 10-Q for the Fiscal Quarter Ended September 30, 3018 | |
| Filed October 25, 2018 | |
| File No. 001-32871 | |
| NBCUniversal Media, LLC | |
| Form 10-K for the Fiscal Year Ended December 31, 2017 | |
| Filed January 31, 2018 | |
| Form 10-Q for the Fiscal Quarter Ended September 30, 2018 | |
| Filed October 25, 2018 | |
| File No. 001-36438 | |
Dear Messrs. Cascarano and Littlepage:
We are writing this letter to respond to the comment letters of the Staff of the Securities and Exchange Commission (the “Staff”) dated November 5, 2018, to Comcast Corporation (“Comcast”) and NBCUniversal Media, LLC (“NBCUniversal”), relating to the review of Comcast’s and NBCUniversal’s combined Form 10-K for the fiscal year ended December 31, 2017 (the “Form 10-K”) and the combined Form 10-Q for the Fiscal Quarter Ended September 30, 2018 (the “Form 10-Q”). Because the questions asked in the comment letters are identical in all respects, except for page number references, we are providing a consolidated response to both letters. In our response, we refer to Comcast and NBCUniversal collectively as “we,” “our” and “us.”
For your convenience, we have reproduced the Staff’s comment in italics preceding our response below. Please let us know if you have any questions or if we can provide additional information or otherwise be of assistance in expediting the review process.
| Securities and Exchange Commission | November 7, 2018 |
Form 10-Q for the Fiscal Quarter Ended September 30, 2018
Comcast Corporation Financial Statements
Note 3: Revenue
NBCUniversal Segments
Distribution, page 11
NBCUniversal Media, LLC Financial Statements
Note 3: Revenue
Distribution, page 61
1. We note your response to prior comment 1. Please revise your disclosure in future filings to clarify that you consider your distribution agreements to be functional licenses of intellectual property. Please refer to ASC 606-10-50-12.
Response
In consideration of the Staff’s comment, beginning with our Annual Report on Form 10-K for the year ending December 31, 2018, we will revise our disclosure to state that we account for our distribution agreements as functional licenses of intellectual property.
* * *
Please do not hesitate to call me at (215) 286-6053 with any questions you may have with respect to the foregoing.
|
Sincerely,
/s/ Daniel C. Murdock | |
|
Daniel C. Murdock Senior Vice President, Chief Accounting Officer and Senior Vice President, NBCUniversal Media, LLC
|
| cc: |
Brian L. Roberts, Chairman of the Board and Chief Executive Officer Michael J. Cavanagh, Chief Financial Officer Arthur R. Block, Executive Vice President, General Counsel and Secretary Jeffrey A. Honickman, Director and Chairman of Audit Committee Bruce K. Dallas, Davis Polk & Wardwell LLP John Malvisi, Deloitte & Touche LLP Courtney Sachtleben, Deloitte & Touche LLP |
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