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United States securities and exchange commission logo
February 3, 2021
Jay Johnson
Chief Financial Officer
LAMAR ADVERTISING CO/NEW
5321 Corporate Blvd.
Baton, Rouge, LA 70808
Re: LAMAR ADVERTISING
CO/NEW
Form 10-K for the
year ended December 31, 2019
Filed February 20,
2020
File No. 001-36756
Dear Mr. Johnson:
We have reviewed your January 5, 2021 response to our comment
letter 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 our comment, we may have
additional
comments. Unless we note otherwise, our reference to a prior comment is
to the comment in our
December 23, 2020 letter.
Form 10-K for the year ended December 31, 2019
Item 8. Financial Statements
(2) Revenue, page 58
1. Please address the
following with respect to your response to our prior comment:
Please provide us
with a more detailed description of the design process for all
revenue sources.
Your discussion should include a description of the involvement of
both the customer
and the company in the design of the advertisement, and the rights
and obligations of
each party. In your response, please address how you considered
the guidance in ASC
Topic 842-10-15-20b.
With respect to
transit and airport advertising revenues, please clarify for us the
nature of the
arrangement that permits you to sell advertising space on the identified
asset. Tell us
whether you own and operate the identified asset, own a billboard
Jay Johnson
LAMAR ADVERTISING CO/NEW
February 3, 2021
Page 2
attached to the identified asset or have entered into a contractual
arrangement with
the owner of the identified asset that allows you to display
advertisements. If your
ability to sell advertising space on the identified asset is derived
from a contractual
arrangement, please provide us with a summary of the typical terms of
those
contracts.
You may contact Howard Efron, Staff Accountant, at 202-551-3439 or
Robert Telewicz,
Branch Chief, at 202-551-3438 if you have questions regarding comments on the
financial
statements and related matters.
Sincerely,
FirstName LastNameJay Johnson
Division of
Corporation Finance
Comapany NameLAMAR ADVERTISING CO/NEW
Office of Real
Estate & Construction
February 3, 2021 Page 2
cc: Michelle Earley
FirstName LastName