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United States securities and exchange commission logo
October 19, 2021
Brian L. Roberts
Chairman and Chief Executive Officer
Comcast Corporation
One Comcast Center
Philadelphia , PA 19103
Re: Comcast Corporation
Form 10-K for
Fiscal Year Ended December 31, 2020
Response dated
September 28, 2021
File No. 001-32871
Dear Mr. Roberts:
We have reviewed your September 28, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
September 14, 2021 letter.
Response dated September 28, 2021
General
1. Your response to prior
comment 1 refers to current or pending climate-related laws and
regulations in the
jurisdictions where you operate. Explain in greater detail how you
determined whether
these laws and regulations are reasonably likely to have a material
effect on you. Also,
tell us how you considered providing disclosure regarding the
difficulties involved
in assessing the timing and effect of pending climate-related laws or
regulations.
2. Your response to prior
comment 2 states that you have not experienced material indirect
consequences of
climate-related regulation or business trends and that you do not believe
any such trends are
reasonably likely to have a material impact on your business, results
of operations or
financial condition. Please describe the indirect consequences you
Brian L. Roberts
Comcast Corporation
October 19, 2021
Page 2
considered in your analysis and explain how you concluded they were
not material.
3. Your response to prior comment 3 states that severe weather events
have impacted your
business and operations for many years and discusses some severe
weather mitigation
efforts; however, it does not appear to discuss the significant
physical effects of climate
change, such as effects on the severity of weather, on your operations
and results.
Accordingly, please revise to discuss the physical effects of climate
change on your
operations and results or explain in greater detail how you concluded
that such effects
have been, and are expected to continue to be, immaterial to your
operations and results.
In order to help us assess your response, please provide a
quantification of material
weather-related damages to your property or operations, a discussion
of how weather-
related impacts have affected or may affect your customers and
suppliers and a discussion
of any weather-related impacts on the cost or availability of
insurance.
4. We note from your response to prior comment 3 that capital
expenditures for your
climate-related projects have not, to date, been a material component
of your capital
expenditures. Please provide us with additional detail supporting this
statement, including
quantitative information.
5. Your response to prior comment 4 appears to focus on your transition
to carbon neutrality
by 2035 and concludes that you do not anticipate costs connected to
this goal to be
material to your results of operations or financial condition. Please
tell us more about
how you considered providing disclosure quantifying the estimated
costs of achieving
your carbon neutral goal and explain how you analyzed the materiality
of these costs.
Lastly, please tell us about transition risks related to climate
change separate from those
arising from your carbon neutral goal and explain how you considered
providing
disclosure regarding their possible effects.
6. Your response to prior comment 5 states that while annual compliance
costs related to
climate change have increased, the increases have not been material to
the company.
Please tell us about the nature of the compliance costs incurred,
quantify the increased
amounts and explain how you analyzed the materiality of these
increases.
Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or
Anna Abramson,
Staff Attorney, at (202) 551-4969 with any questions.
FirstName LastNameBrian L. Roberts Sincerely,
Comapany NameComcast Corporation
Division of
Corporation Finance
October 19, 2021 Page 2 Office of
Technology
FirstName LastName