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United States securities and exchange commission logo
December 23, 2020
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 limited our review of your filing to the financial
statements and related
disclosures 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 our 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.
Form 10-K for the year ended December 31, 2019
Item 8 Financial Statements
(2) Revenue, page 58
1. We note your disclosure
that the majority of your advertising space contracts do not meet
the definition of a
lease under ASC 842. Please provide us with a summary of the typical
terms of your
advertising space contracts by source (i.e. billboard, logo and transit) and
explain to us how you
determined these contracts do not meet the definition of a lease. In
your response, please
tell us the amount of revenue for the year ended December 31, 2019
and quarterly period
ended September 30, 2020 for each source derived from contracts
that do meet the
definition of a lease, and explain to us how these contracts differ from
those contracts that
are not leases.
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
Jay Johnson
LAMAR ADVERTISING CO/NEW
December 23, 2020
Page 2
absence of action by the staff.
You may contact Howard Efron, Staff Accountant, at 202-551-3439 or Robert
Telewicz,
Branch Chief, at 202-551-3438 with any questions.
Sincerely,
FirstName LastNameJay Johnson
Division of Corporation
Finance
Comapany NameLAMAR ADVERTISING CO/NEW
Office of Real Estate &
Construction
December 23, 2020 Page 2
cc: Michelle Earley
FirstName LastName