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