May 23, 2019
VIA EDGAR AND OVERNIGHT DELIVERY
Ms. Suying Li
Mr. Rufus Decker
Division of Corporation Finance Office of Beverages, Apparel and Mining
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
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Re: |
Molson Coors Brewing Company |
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Form 10-K for Fiscal Year Ended December 31, 2018 |
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Filed February 12, 2019 |
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Form 8-K Filed February 12, 2019 |
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File No. 001-14829 |
Dear Ms. Li and Mr. Decker:
Molson Coors Brewing Company (the “Company,” “we,” and “our”) submits this response to the comment set forth in the comment letter of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated May 14, 2019 relating to the above-referenced Current Report on Form 8-K. For convenience, the Staff’s comment is set forth below in italics followed by the Company’s response.
Form 8-K Filed February 12, 2019
Exhibit 99.1
Appendix, page 13
1. You present full non-GAAP income statements when reconciling non-GAAP measures to the most directly comparable GAAP measures. Please tell us how you considered the guidance in Question 102.10 of the Division’s Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
Response: We respectfully acknowledge the Staff’s comment and undertake that in future filings with the Commission and earnings releases we will reconcile our non-GAAP measures to the most directly comparable GAAP measures without presenting full non-GAAP income statements.
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1801 California Street · 46th Floor · Denver, Colorado · 80202 · USA
Tel. (303) 927-2337
MOLSON is a registered trademark of Molson Canada 2005, used under license. COORS is a registered trademark of Coors Brewing Company, used under license.