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July 10, 2018
Katherine L. Scherping
Chief Financial Officer
National CineMedia, Inc.
9110 East Nichols Ave.
Suite 200
Centennial, CO 80112
Re: National CineMedia, Inc.
Form 10-K for Fiscal Year Ended December 28, 2017
Filed March 19, 2018
Form 10-Q for Fiscal Quarter Ended March 29, 2018
Filed May 8, 2018
File No. 001-33296
Dear Ms. Scherping:
We have limited our review of your filings to the financial statements
and related
disclosures 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.
Form 10-K for Fiscal Year Ended December 28, 2017
Note 18. Correction of an Error, page F-37
1. Please clearly explain to us, in detail, the nature of the errors in your
previously issued
financial statements including a reference to the specific accounting
literature that was
misapplied. Provide us an explanation of you prior accounting and how you
corrected it
including how you determined the correction amounts. Also tell us why it
was necessary
to adjust each of the balance sheet line-items in the table on page F-38.
2. Please provide us with your assessment of the materiality of the errors
identified in your
Katherine L. Scherping
National CineMedia, Inc.
July 10, 2018
Page 2
historical financial statements. We refer you to the guidance in SAB
Topics 1:M and 1:N.
Form 10-Q for Fiscal Quarter Ended March 29, 2018
Change in Accounting Principle and Correction of an Error, page 9
3. Please explain to us the facts and circumstances concerning the change
in accounting
principle, including an explanation of previous generally accepted
accounting principle
and the newly adopted generally accepted accounting principle. Provide
us specific
references in the accounting literature as support for both the newly
adopted and previous
accounting policies.
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.
You may contact Joseph Cascarano, Staff Accountant, at 202-551-3376 or
Robert S.
Littlepage, Accountant Branch Chief, at 202-551-3376 with any questions.
FirstName LastNameKatherine L. Scherping
Comapany NameNational CineMedia, Inc.
Division of
Corporation Finance
July 10, 2018 Page 2 Office of
Telecommunications
FirstName LastName