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United States securities and exchange commission logo
December 13, 2023
Jennifer Leyden
Chief Financial Officer
Getty Images Holdings, Inc.
605 5th Ave. S. Suite 400
Seattle, WA 98104
Re: Getty Images
Holdings, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2022
Form 10-Q for
Fiscal Quarter Ended June 30, 2023
File No. 001-41453
Dear Jennifer Leyden:
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
Liquidity and Capital Resources
Cash Flows, page 56
1. Please provide an
analysis of why the reported amount of operating cash flows materially
changed from period to
period for annual and interim periods. Refer to Item 303 of
Regulation S-K. Your
current discussion appears to be a recitation of the items presented
in your statement of
cash flows of how the amount of operating cash flows was derived
for each period. Your
discussion also refers to noncash items that do not impact
cash. Note references
to results and working capital items may not provide a sufficient
basis to understand how
the amount of operating cash actually was affected between
periods. Your analysis
should discuss all material factors that actually affected the
reported amount of
operating cash and reasons for material changes between periods
underlying these
factors. Refer to the introductory paragraph of section IV.B and B.1 of
Release No. 33-8350 for
further guidance.
Jennifer Leyden
Getty Images Holdings, Inc.
December 13, 2023
Page 2
Notes to Consolidated Financial Statements
Note 14. Revenue, page F-28
2. Please tell us your consideration of disclosing disaggregated revenue
by product offering
as disclosed on page 5. We note that your content type, key customers,
and go-to-market
approach differ between the Getty Images, iStock, and Unsplash product
offerings. Refer
to ASC 606-10-50-5 and 50-6 and ASC 606-10-55-89 through 55-91.
Form 10-Q for Fiscal Quarter Ended June 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Comparison of the Three Months Ended June 30, 2023 and 2022, page 23
3. In your third quarter earnings call on November 14, 2023, your CFO
stated "Creative
results reflect pressures in the agency segment, which was double
digits year-on-year as
well as impact from the Hollywood strike" and that your updated
guidance "assumes
continued macroeconomic pressures, adverse impacts from the Hollywood
strike and
pressures on our agency business through Q4." Please enhance your
discussion in your
periodic filings for any unusual or infrequent events and/or
significant economic changes
that have impacted or are reasonably likely to materially impact your
revenue and income
from operations in future periods. Refer to Item 303(a) and (b)(2)(i)
and (ii) of Regulation
S-K, the latter as guided by the last sentence of 303(c).
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 Robert Shapiro at 202-551-3273 or Doug Jones at
202-551-3309 with any
questions.
FirstName LastNameJennifer Leyden Sincerely,
Comapany NameGetty Images Holdings, Inc.
Division of
Corporation Finance
December 13, 2023 Page 2 Office of Trade
& Services
FirstName LastName