United States securities and exchange commission logo
April 1, 2022
Robert Blair
General Counsel
VIASAT INC
6155 El Camino Real
Carlsbad, California 92009
Re: VIASAT INC
Amendment No. 1 to
Preliminary Proxy Statement on Schedule 14A
Filed March 18,
2022
File No. 000-21767
Dear Mr. Blair:
We have reviewed your filing 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.
Preliminary Proxy Statement on Schedule 14A, Amendment No. 1
Inmarsat Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Year Ended December 31, 2020 vs. Successor Period, Predecessor Period,
and Pro Forma Year
Ended December 31, 2019, page 97
1. We note your revisions
made in response to our prior comment number 11. However,
please be advised that
pro forma discussions based upon Article 11 of Regulation S-X
should not be presented
with the discussion of historical financial statements required by
Item 303(b) of
Regulation S-K. In this regard, we note you have included the pro forma
results within the same
paragraph discussion of the historical periods. As such, please
revise your discussion
to separately compare the historical results of the respective
successor and
predecessor periods ended December 31, 2020, 2019 and 2018, from your
supplemental discussion
of the pro forma results.
Robert Blair
VIASAT INC
April 1, 2022
Page 2
General
2. We note your disclosure throughout your proxy statement that the
proposed transaction
with Inmarsat is subject to certain regulatory approvals. Please
update your disclosure
where applicable to reflect whether such regulatory approvals have
been obtained and
under what conditions, if any.
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.
You may contact Beverly Singleton, Staff Accountant, at (202) 551-3328
or Jean Yu,
Assistant Chief Accountant, at (202) 551-3305 if you have questions regarding
comments on the
financial statements and related matters. Please contact Bradley Ecker, Staff
Attorney, at (202)
551-4985 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with any
other questions.
FirstName LastNameRobert Blair Sincerely,
Comapany NameVIASAT INC
Division of
Corporation Finance
April 1, 2022 Page 2 Office of
Manufacturing
FirstName LastName