SEC – ‘UPLOAD’ from 3/16/23 re: Paramount Global – ‘TEXT-EXTRACT’

On:  Thursday, 3/16/23, at 11:30am ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed   ·   Accession #:  0-23-2602

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Comment or Other Letter from the SEC   —   Delayed-Release

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                 PDF     39K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC - PDF's         2±     8K 
                Text                                                             

‘TEXT-EXTRACT’   —   Comment or Other Letter from the SEC – PDF’s Text

United States securities and exchange commission logo                           

March 16, 2023      

Naveen Chopra                                                     
Chief Financial Officer                                           
Paramount Global                                                  
1515 Broadway                                                     
New York, New York 10036                                          

                                                    Re: Paramount Global
                                                         Form 10-K for the
Fiscal Year Ended December 31, 2022                                             
                                                          File No. 001-09553
                                                          Filed February 16,
2023                                                                            

Dear Naveen Chopra:                                               

            We have reviewed your filing 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 the Fiscal Year Ended December 31, 2022             

Critical Accounting Policies                                      
Goodwill and Intangible Assets Impairment Tests, page II-37       

1.                                                   It appears that your 
goodwill balance exceeds your market capitalization. Tell us and                
                                                disclose how you
considered market capitalization when performing your goodwill                  
                                                   impairment testing.

2.                                                   Given the significant
balance of your goodwill and significant judgments involving                    
                                                   goodwill impairment
testing, please consider disclosing in future filings the balance of            
                                                 goodwill for each
reporting unit.                                                                 

 3.                                                   Tell us why the fourth
quarter 2022 management reorganization resulted in a change to                  
                                                    your reporting units
within the TV Media segment. Also, explain in further detail why a              
Naveen Chopra                                                                 
Paramount Global                                                                
March 16, 2023                                                                  
Page 2                                                                          
        quantitative impairment test was not performed for each reporting unit
prior to and post                                                               
the fourth quarter reorganization.                            
     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 Inessa Kessman, Senior Staff Accountant, at     
202-551-3371 or Robert                                                          
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have any questions. 

FirstName LastNameNaveen Chopra                               Sincerely,        
Comapany NameParamount Global                                                   
                                                       Division of
Corporation Finance                                                             
March 16, 2023 Page 2                                         Office of         
Technology                                                                      
FirstName LastName                                                              

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Filed on:		3/16/23		UPLOAD
		2/16/23		10-K,  8-K,  UPLOAD
		12/31/22		10-K,  ARS
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 2/16/23  Paramount Global                  10-K       12/31/22  151:23M