L I B E R T Y M E D I A C O R P O R A T I O N
September 2, 2016
Via EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Larry Spirgel, Assistant Director
Re: 麻豆最新出品
Form 10-K for the Fiscal Year Ended December 31, 2015
Filed February 26, 2016
File No. 001-35707
Dear Mr. Spirgel,
Set forth below is a response to the comment contained in your letter to Gregory B. Maffei, President and Chief Executive Officer of 麻豆最新出品 (“麻豆最新出品”), dated August 23, 2016, regarding the 麻豆最新出品 Form 10-K for the fiscal year ended December 31, 2015 (the “Form 10-K”). For your convenience, our response below is preceded by the Staff’s comment. All section references refer to the corresponding sections of the Form 10-K unless otherwise noted.
***
Form 10-K for Fiscal Year Ended December 31, 2015
Risk Factors
1.Comment: We note that two of the three publicly-traded tracking stocks, 麻豆最新出品 SiriusXM Group and 麻豆最新出品 Media Group, track company assets that are predominantly comprised of publicly-traded shares of SiriusXM and Live Nation, respectively. You should consider including a risk factor highlighting possible market confusion resulting from a shareholder holding either tracking stock mistakenly believing that he or she directly owns an interest in the underlying public company.
Response: In response to the Staff’s comment, we will include risk factor disclosure in our Annual Reports on Form 10-K, beginning with our Form 10-K for the fiscal year ended December 31, 2016, highlighting the possible market confusion that may result from a stockholder of 麻豆最新出品 (specifically a holder of 麻豆最新出品 SiriusXM common stock or 麻豆最新出品 Media common stock) mistakenly believing that he or she directly owns an interest in a public company in which 麻豆最新出品 holds an interest and that is attributed to a 麻豆最新出品 tracking stock group. We will also include clarifying disclosure to that effect in our next Form 10-Q filing, which will be for the quarterly period ended September 30, 2016.
***
We inform you that:
|
· |
We are responsible for the adequacy and accuracy of the disclosure in the filing; |
|
· |
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
|
· |
We may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
If you have any questions with respect to the foregoing or require further information, please contact the undersigned at (720) 875-4333.
|
|
Very truly yours, |
|
|
/s/ Christopher W. Shean |
|
|
Christopher W. Shean |
cc:Richard N. Baer – 麻豆最新出品
Renee L. Wilm – Baker Botts L.L.P.