View:
United States securities and exchange commission logo
September 28, 2020
Deborah Thomas
Executive Vice President and Chief Financial Officer
HASBRO, INC.
1027 Newport Avenue
Pawtucket, Rhode Island 02861
Re: HASBRO, INC.
Form 10-K for the
period ended December 29, 2019
Filed February 27,
2020
File No. 001-06682
Dear Ms. Thomas:
We have limited our review of your filing 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 the period ended December 29, 2019
Management's Discussion and Analysis
Results of Operations, page 38
1. We note your chart
disclosing the change in net revenues by brand portfolio for each year
in the three years
ended December 29, 2019. In the accompanying discussion of the
variances, by
portfolio, you identify component product brands and discuss the general
impact they had on the
growth, or decline, in net reveunes but do not otherwise quantify
their impact. In future
filings, please revise your disclosures to quantify the reasons for
the change in order for
an investor to discern the relative contribution of each of the
multiple components
cited to the total change. The impacts of material variances in
identified components
that offset each other should be separately disclosed, quantified,
and discussed rather
than netting them. Please provide us with examples of your intended
disclosures based on
current financial results. Refer to FR-72 for additional guidance.
Deborah Thomas
HASBRO, INC.
September 28, 2020
Page 2
Notes to Consolidated Financial Statements
Revenue Recognition, page 72
2. You disclose the launch of MAGIC: THE GATHERING ARENA, a free-to-play
online
adaptation of the MAGIC: THE GATHERING card game, late in the third
quarter of
2019. In your revenue recognition policy, you disclose that "end users
make in-
application purchases of virtual currencies, via the Company s
platform providers, with
such purchased virtual currencies to be used in the games. The Company
records revenues
from in-application purchases based on either the usage patterns of
the players or the
player s estimated life." In addition, you disclose that digital
game revenues are
recognized within six months of purchase. To help us better understand
your disclosure
please address the following:
Describe your policy for refunds related to in-game purchases.
Can virtual currency expire if unused?
Can virtual currency be transferred or otherwise sold by the
customer?
Describe what a 'usage pattern' is and how that pattern is used
to determine the timing
of revenue recognition.
For player accounts that have un-recognized deferred revenue,
what is your policy for
recognizing the related revenue in cases where the account
appears to be inactive?
Clarify how you determine whether you are the principal or the
agent in the
arrangements with the third-party platform providers, given it
appears that you
recognize some revenue on a gross basis and some on a net basis.
In your response,
tell us the amounts of revenue recognized on a gross basis and on
a net basis for the
periods presented.
You have disclosed that revenues are recognized within six
months. Tell us how this
timing aligns with the player's estimated life. If the estimated
player's life is longer
than six months, tell us what impact that has, if any, on the
timing of revenue
recognition.
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 Charles Eastman, Staff Accountant, at (202) 551-3794 or
Melissa
Raminpour, Accounting Branch Chief, at (202) 551-3379 with any questions.
FirstName LastNameDeborah Thomas Sincerely,
Comapany NameHASBRO, INC.
Division of
Corporation Finance
September 28, 2020 Page 2 Office of
Manufacturing
FirstName LastName