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United States securities and exchange commission logo
May 14, 2024
Kyle Lorentzen
Chief Fianancial Officer
CommScope Holding Company, Inc.
3642 E. US Highway 70
Claremont , North Carolina 28610
Re: CommScope Holding
Company, Inc.
Form 10-K for the
year ended February 29, 2024
Form 10-Q for the
Period Ended March 31, 2024
File No. 001-36146
Dear Kyle Lorentzen:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 10-Q for the Period Ended March 31, 2024
Notes to Unaudited Condensed Consolidated Financial Statements
Asset Impairments
Goodwill, page 9
1. We note that you
performed a goodwill impairment test before and after the change in the
composition of your
reporting units and that no impairment existed and none was
identified during the
three months ended March 31, 2024. Please tell us if you performed
impairment testing at
March 31, 2024. Given the deterioration in your operating results
(i.e., decreases in net
sales, operating income and cash flows from operations) and the
outlook for the
remainder of 2024, tell us and disclose in future filings the percentage by
which your estimated
fair value exceeded its carrying value for each reporting unit and the
specific key
assumptions used in the fair value determination as of the date of your most
recent impairment test.
Please refer to Item 303(b)(3) of Regulation S-K.
Form 10-K for the year ended February 29, 2024
Kyle Lorentzen
CommScope Holding Company, Inc.
May 14, 2024
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies and Estimates, page 45
2. Please enhance your disclosures to provide qualitative and
quantitative information
necessary to understand the estimation uncertainty and the impact your
critical accounting
estimates have had or are reasonably likely to have on your financial
condition and results
of operations. In addition, discuss how much each estimate and/or
assumption has
changed over a relevant period and the sensitivity of reported amounts
to the underlying
methods, assumptions and estimates used. The disclosures should
supplement, not
duplicate, the description of accounting policies or other disclosures
in the notes to the
financial statements. Refer to Item 303(b)(3) of Regulation S-K and
SEC Release No. 33-
8350.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Charles Eastman at 202-551-3794 or Melissa Gilmore at
202-551-3777
with any questions.
FirstName LastNameKyle Lorentzen Sincerely,
Comapany NameCommScope Holding Company, Inc.
Division of
Corporation Finance
May 14, 2024 Page 2 Office of
Manufacturing
FirstName LastName