View:
United States securities and exchange commission logo
July 14, 2021
Paul W. Orban
Executive Vice President and Chief Financial Officer
DISH DBS Corporation
9601 South Meridian Boulevard
Englewood, CO 80112
Re: DISH DBS
Corporation
Form 10-Q for the
Quarterly Period Ended March 31, 2021
Filed May 4, 2021
File No. 333-3192
Dear Mr. Orban:
We have reviewed your July 2, 2021 response to our comment
letter and have the
following comment. In our comment, we 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. Unless we note otherwise, our references to prior comments are
to comments in our
June 23, 2021 letter.
Form 10-Q for the Quarterly Period Ended March 31, 2021
Financial Statements
Note 10. Financial Information for Subsidiary Guarantors, page 29
1. The disclosures
specified in Rule 13-01(a) of Regulation S-X are required for each
guaranteed security
subject to Section 13(a) or 15(d) of the Securities Exchange Act of
1934. Based on Exhibit
22 filed in response to prior comment 1, we note that Sling TV
Holding L.L.C. is a
subsidiary that guarantees the 7.375% Senior Notes due 2028 issued
by DISH DBS
Corporation, but does not guarantee the other Senior Notes listed therein.
Please tell us how you
considered this difference in subsidiary guarantors in the financial
and non-financial
disclosures required by Rule 13-01 included in your Form 10-Q, and
whether separate
disclosures distinguishing between each issuer and guarantor structure
and/or guaranteed
security are necessary.
Paul W. Orban
DISH DBS Corporation
July 14, 2021
Page 2
You may contact Joyce Sweeney, Senior Staff Accountant, at 202-551-3449
or
Kathleen Collins, Accounting Branch Chief, at 202-551-3499 with any questions.
FirstName LastNamePaul W. Orban Sincerely,
Comapany NameDISH DBS Corporation
Division of Corporation
Finance
July 14, 2021 Page 2 Office of Technology
FirstName LastName