SEC Comment Letter for ABBOTT LABORATORIES (ABT) — Apr 30, 2008
ABBOTT LABORATORIES
Date: April 30, 2008 · CIK: 0000001800 · Accession: 0000000000-08-022254
AI Filing Summary & Sentiment
File numbers found in text: 001-02189
Letter
Mail Stop 6010 April 30, 2008 Mr. Miles D. White Chairman and Chief Executive Officer Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064-6400 Re: Abbott Laboratories Form 10-K for Fiscal Year ended December 31, 2007 Filed February 19, 2008 File No. 001-02189
Dear Mr. White:
We have reviewed your filing and have the following comments. In our comments, we ask you to provide us with information to better understand your disclosure. Where a comment requests you to revise disclosure, the information you provide should show us what the revised disc losure will look like and identify the annual or quarterly filing, as appli cable, in which you intend to first include it. If you do not believe that revised disclosure is necessary, explain the reason in your response. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the year ended December 31, 2007
Item 1. Business
International Operations, page 8
1. We note your disclosure that you market products in approxim ately 130 countries through affiliates and distribu tors. In a supplemental res ponse, please advise us as to whether you conduct business with Sudan, Iran, Syria, North Korea, or Cuba.
Mr. Miles D. White Abbott Laboratories April 30, 2008 Page 2
Item 15. Exhibits, Financial Statement Schedules
2. We note that you have described your acquisition agreement regarding Kos Pharmaceuticals Inc., but did not file it as an exhibit. Please file this agreement as an exhibit or provide us with an anal ysis supporting your determination that the agreement is not required to be filed pu rsuant to Item 601 (b)(10) of Regulation S- K. Please note that if this agreemen t was filed previously, you may amend your Form 10-K to incorporate the previo usly-filed agreement by reference.
* * * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please provide us any requested information. Detailed cover letters greatly facilitate our review. Please file the letter on EDGAR under the form type label CORRESP. We urge all persons who are responsi ble for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclosure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing. Please do not hesitate to contact Rose Zukin at (202) 551-3239 or me at (202) 551-3715 if you have questions regarding th e comments and related matters.
Mr. Miles D. White Abbott Laboratories April 30, 2008 Page 3
Sincerely,
Jeffrey Riedler Assistant Director
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Mail Stop 6010 April 30, 2008 Mr. Miles D. White Chairman and Chief Executive Officer Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064-6400 Re: Abbott Laboratories Form 10-K for Fiscal Year ended December 31, 2007 Filed February 19, 2008 File No. 001-02189 Dear Mr. White: We have reviewed your filing and have the following comments. In our comments, we ask you to provide us with information to better understand your disclosure. Where a comment requests you to revise disclosure, the information you provide should show us what the revised disc losure will look like and identify the annual or quarterly filing, as appli cable, in which you intend to first include it. If you do not believe that revised disclosure is necessary, explain the reason in your response. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the year ended December 31, 2007 Item 1. Business International Operations, page 8 1. We note your disclosure that you market products in approxim ately 130 countries through affiliates and distribu tors. In a supplemental res ponse, please advise us as to whether you conduct business with Sudan, Iran, Syria, North Korea, or Cuba. Mr. Miles D. White Abbott Laboratories April 30, 2008 Page 2 Item 15. Exhibits, Financial Statement Schedules 2. We note that you have described your acquisition agreement regarding Kos Pharmaceuticals Inc., but did not file it as an exhibit. Please file this agreement as an exhibit or provide us with an anal ysis supporting your determination that the agreement is not required to be filed pu rsuant to Item 601 (b)(10) of Regulation S- K. Please note that if this agreemen t was filed previously, you may amend your Form 10-K to incorporate the previo usly-filed agreement by reference. * * * * * Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please provide us any requested information. Detailed cover letters greatly facilitate our review. Please file the letter on EDGAR under the form type label CORRESP. We urge all persons who are responsi ble for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclosure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States. In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing. Please do not hesitate to contact Rose Zukin at (202) 551-3239 or me at (202) 551-3715 if you have questions regarding th e comments and related matters. Mr. Miles D. White Abbott Laboratories April 30, 2008 Page 3 Sincerely, Jeffrey Riedler Assistant Director