United States securities and exchange commission logo
December 19, 2023
Frank Lanuto
Chief Financial Officer
Stagwell Inc.
One World Trade Center, Floor 65
New York, NY 10007
Re: Stagwell Inc.
Form 10-K for
Fiscal Year Ended December 31, 2022
File No. 001-13718
Dear Frank Lanuto:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations
Year Ended December 31, 2022 Compared to Year Ended December 31, 2021
Consolidated Results of Operations
Net Revenue, page 47
1. Please clarify for us
in further detail what the Net Acquisitions (Divestitures) and
the organic revenue
growth/decline change components represent and how they are
calculated. If helpful,
please provide a numerical example of the calculations.
Notes to Consolidated Financial Statements
20. Segment Information, page 113
2. Given you generated
approximately 17.5% of your total revenues outside of the United
States in 2022 and
maintain office space in Africa, Europe, Asia, South America, and
Australia, please tell
us your consideration of providing long-lived assets geographic
Frank Lanuto
Stagwell Inc.
December 19, 2023
Page 2
information in accordance with ASC 280-10-50-41, or revise. If
providing this disclosure
is impracticable (which is expected to be rare), please tell us the
specific aspects of
providing this disclosure that are impracticable and explain in detail
why each aspect is
impracticable. If your impracticability assertion for one or more
specific aspects surrounds
excessive cost, please also demonstrate how you determined the cost
would be excessive.
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.
Please contact Aamira Chaudhry at 202-551-3389 or Stephen Kim at
202-551-3291 with
any questions.
FirstName LastNameFrank Lanuto Sincerely,
Comapany NameStagwell Inc.
Division of
Corporation Finance
December 19, 2023 Page 2 Office of Trade
& Services
FirstName LastName