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October 4, 2021
Roger Byrd
General Counsel
EASTMAN KODAK CO
343 State Street
Rochester, NY 14650
Re: EASTMAN KODAK CO
Form 10-K filed
March 16, 2021
Correspondence
filed September 13, 2021
File No. 001-00087
Dear Mr. Byrd:
We have reviewed your September 13, 2021 response to our
September 1, 2021 comment
letter and have the following comments. In some of our comments, we may
ask you to provide
us with information so we may better understand your disclosure. Please
respond to these
comments 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 comments
apply to your facts and
circumstances, please tell us why in your response. After reviewing your
response to these
comments, we may have additional comments.
Correspondence filed September 13, 2021
Pensions and Other Postretirement Benefits, page 31
1. Please expand the
disclosure on page 31 to address the historical accuracy of your specific
plan asset fair value
estimates. Given the apparent absence of a readily determinable fair
value for the vast
majority of your Major U.S. Pension Plan Assets, it is not clear whether
a material portion of
such assets have historically been sold at amounts significantly
different from the
corresponding net asset value per share amounts disclosed in your
filings.
2. It appears from your
disclosure on page 91 that a substantial portion of the assets
characterized as Equity
and Debt Securities presented in the table on page 88 are actually
derivative instruments
and not stocks or bonds. The distinction appears relevant since your
loss exposure on
derivative instruments may be materially different than your loss
exposure on holdings of
stocks or bonds. Further, the presentation of "Derivatives" line
items in the table
could be confusing since the corresponding dollar amounts exclude
almost all of your
actual derivatives holdings. Please revise.
Roger Byrd
EASTMAN KODAK CO
October 4, 2021
Page 2
3. Please clarify for us how you determined that your derivatives
holdings lack a readily
determinable fair value as contemplated by ASC 820-10-15-4. The
guidance in ASC 815-
10-35 may be relevant.
4. It remains unclear whether your loss exposure on these derivatives
could materially
exceed the carrying value of the investments. Please provide a
disclosure that clarifies this
issue and identifies all known factors that could precipitate material
losses in your existing
derivatives portfolio such as increases in interest rates, decreases
in company-specific or
sector-specific equity prices, etc. For example, your proposed
disclosure does not indicate
whether a material increase in interest rates would reasonably be
expected to generate a
material net loss on the derivative contracts owned by the Plan at the
Balance Sheet date.
See Section 501.02 of the Financial Reporting Codification.
You may contact Al Pavot at (202) 551-3738 or Terence O'Brien at (202)
551-3355 if
you have questions.
FirstName LastNameRoger Byrd Sincerely,
Comapany NameEASTMAN KODAK CO
Division of
Corporation Finance
October 4, 2021 Page 2 Office of Life
Sciences
FirstName LastName