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United States securities and exchange commission logo
July 17, 2023
Alejandro Ortiz
General Counsel
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, Nuevo Le n 64410, M xico
Re: Mexican Economic
Development, Inc.
Form 20-F for the
Fiscal Year Ended December 31, 2022
Filed April 24,
2023
File No. 001-35934
Dear Alejandro Ortiz:
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 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 this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Financial Statements
Note 3.18 Intangible Assets, page F-33
1. We note your accounting
policy and disclosures regarding your treatment of TCCC
bottling agreement
intangible assets as indefinite lived intangible assets even though they
have a stated term of
10 years and contain a 10 year renewal right. We also note your
policy may be
inconsistent with other entities with similar assets. Please refer
to paragraph 94 of IAS
38 and more fully explain to us why you believe your accounting
policy is appropriate
and consistent with IFRS, given the stated term of the agreements.
In addition, please
explain to us the process and expected costs of renewing
the agreements at the
end of their 10 year term and how you concluded renewals are
essentially perpetual
in nature.
Alejandro Ortiz
Mexican Economic Development, Inc.
July 17, 2023
Page 2
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
absence of action by the staff.
You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at
202-551-3723 with
any questions.
FirstName LastNameAlejandro Ortiz Sincerely,
Comapany NameMexican Economic Development, Inc.
Division of
Corporation Finance
July 17, 2023 Page 2 Office of
Manufacturing
FirstName LastName