View:
October 22, 2018
Sean Sullivan
Executive Vice President and Chief Financial Officer
AMC Networks Inc.
11 Penn Plaza
New York, NY 10001
Re: AMC Networks Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 1, 2018
Form 10-Q for the Quarterly Period Ended June 30, 2018
Filed August 2, 2018
File No. 001-35106
Dear Mr. Sullivan:
We have reviewed your September 6, 2018 response to our comment letter
and have the
following comments. Please comply with the following comments in future
filings. Confirm in
writing that you will do so and explain to us how you intend to comply.
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-Q for the Quarterly Period Ended June 30, 2018
Content licensing revenue, page 7
1. We note your response to prior comment one. Please revise your disclosure
to clarify that
you consider each season of an episodic series to be a distinct unit of
content and that you
typically deliver all episodes of a season for a series concurrently.
Reference ASC 606-
10-50-12.
Subscription fee revenue, page 7
2. We note your response to prior comment two. Please revise your
disclosures to clarify
Sean Sullivan
AMC Networks Inc.
October 22, 2018
Page 2
your determination that your programming is functional intellectual
property. Reference
606-10-50-12.
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371
or Carlos
Pacho, Senior Assistant Chief Accountant at 202-551-3835 with any questions.
FirstName LastNameSean Sullivan Sincerely,
Comapany NameAMC Networks Inc.
Division of
Corporation Finance
October 22, 2018 Page 2 Office of
Telecommunications
FirstName LastName