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United States securities and exchange commission logo
September 3, 2020
Katy Murray
Chief Financial Officer
A. H. Belo Corp
P.O. Box 224866
Dallas, Texas 75222
Re: A. H. Belo Corp
Form 10-K For the
Year Ended December 31, 2019
Filed May 8, 2020
Form 8-K Filed May
8, 2020
File No. 001-33741
Dear Ms. Murray:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we may ask
you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 8-K Filed May 8, 2020
Exhibit 99.1
General
1. We note your discussion
of adjusted operating loss on page 1 of your fourth quarter 2019
earnings release.
Please revise to discuss the most directly comparable GAAP measure
(i.e., operating income
or loss) with equal or greater prominence to avoid placing undue
prominence on the
Non-GAAP measures. Refer to Question 102.10 of the Non-GAAP
Compliance and
Disclosure Interpretations. The same comment applies to your first and
second quarter 2020
earnings releases.
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.
Katy Murray
A. H. Belo Corp
September 3, 2020
Page 2
You may contact SiSi Cheng at 202-551-5004 or John Cash at 202-551-3768
with any
questions.
FirstName LastNameKaty Murray Sincerely,
Comapany NameA. H. Belo Corp
Division of Corporation
Finance
September 3, 2020 Page 2 Office of Manufacturing
FirstName LastName