View:
United States securities and exchange commission logo
May 1, 2024
Steven Tomsic
Chief Financial Officer
Fox Corp
1211 Avenue of the Americas
New York, New York 10036
Re: Fox Corp
Form 10-K for the
Fiscal Year Ended June 30, 2023
File No. 001-38776
Dear Steven Tomsic:
We have reviewed your April 15, 2024 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our March 26,
2024 letter.
Form 10-K for the Fiscal Year Ended June 30, 2023
Notes to Consolidated Financial Statements
Note 17. Segment Information, page 101
1. You indicate Other
is one of your reportable segments, and it consists of four operating
segments and head
office functions. Your footnote disclosure refers to this segment as
Other, Corporate and
Eliminations. Please tell us whether you have aggregated these
operating segments, and
if so, provide us with your analysis supporting aggregation. If
these operating
segments have not been aggregated, whether Other consists of
information about other
business activities and operating segments that are not reportable,
and if so, why Other
is disclosed as a reportable segment. See ASC 280-10-50-11
through -15. Finally,
please tell us whether, and if so why, eliminations have been
combined in Other
rather than presented as part of reconciliations from total reportable
segments amounts to
consolidated totals. See ASC 280-10-50-30 and -31.
Steven Tomsic
Fox Corp
May 1, 2024
Page 2
2. You indicate in your response to prior comment one that revenue
targets are managed at
the consolidated Company-wide and operating segment level. However, it
appears that
revenue and EBITDA targets are established in the budget for certain
Business Units and
Business Components. Please describe budgeting process in more detail.
Explain who
approves the budget at each step of the process, including at the
Business Unit and
Business Component levels. Additionally, explain and how and why
revenue and
EBITDA budgets are developed for Business Units and Business
Components.
3. You indicate in your response to prior comment one that revenue and
EBITDA are not
included in the budget or monthly reporting for the FOX Sports, FOX
Entertainment, and
Tubi Media Group Business Units, but it appears that revenue and
EBITDA are included
for Selected Business Components related to these Business Units.
Please tell us whether
the Business Components that comprise the FOX Sports, FOX
Entertainment, and Tubi
Media Group Business Units are included in each of the budget and
monthly reporting. If
all Business Components comprising these Business Units are not
included, please explain
which ones are included and excluded, and the reasons why.
4. Please describe how leaders of the revenue functions, Business Unit
managers, and
Business Component managers are compensated, including whether any
compensation is
dependent on a measure of profitability at the Business Unit or
Business Component level.
5. We note per your response to our prior comment one that the Board
receives EBITDA for
business components in specific cases. Please explain what these
specific cases are and
clarify what Business Component-level financial information is
provided to the Board,
which Business Components it is provided for, and the frequency.
Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at
202-551-3361 if
you have questions regarding comments on the financial statements and related
matters.
FirstName LastNameSteven Tomsic Sincerely,
Comapany NameFox Corp
Division of
Corporation Finance
May 1, 2024 Page 2 Office of
Technology
FirstName LastName