SEC Comment Letter for ABBOTT LABORATORIES (ABT) — Jan 6, 2011
ABBOTT LABORATORIES
Date: Jan. 6, 2011 · CIK: 0000001800 · Accession: 0000000000-11-000965
AI Filing Summary & Sentiment
File numbers found in text: 001-02189
Letter
January 6, 2011 Thomas C. Freyman CFO & EVP Finance Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064 Re: Abbott Laboratories Form 10-K for the Fiscal Year Ended December 31, 2009 Definitive Proxy Statement on Schedule 14A Filed March 15, 2010 File No. 001-02189
Dear Mr. Freyman: We have reviewed your December 1 0, 2010 response to our November 19, 2010 comment letter and have the following comment. In our comment, we ask you to provide us with information so we may be tter understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Schedule 14A
Executive Compensation Compensation Discussion and Analysis Compensation Components Performance-Based Annual Cash Incentives, page 14
1. Your revised disclosure for 2009 compensa tion provided in response to the prior comment omits various corporate and individu al goals for each named executive officer that appear to be material to your compensa tion process. Please pr ovide draft disclosure of your 2010 compensation that discloses a nd describes all of the corporate and individual goals for each named executive officer . If you believe that one or more of the goals that was established and communicated to your named executive officers is not material, please provide a separate and deta iled analysis for each goal which you believe is not material that supports your conclusi on that such goal is not material to your compensation and the process by which you aw ard compensation. Please also confirm
Thomas C. Freyman Abbott Laboratories January 6, 2011 Page 2
that you will disclose in your next proxy statement your Committee’s evaluation of each goal for each named executive officer.
Please contact Jennifer Riegel at (202 ) 551-3575 or me at (202) 551-3710 with any questions. Sincerely, Jeffrey P. Riedler Assistant Director
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January 6, 2011
Thomas C. Freyman CFO & EVP Finance Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064
Re: Abbott Laboratories
Form 10-K for the Fiscal Year Ended December 31, 2009
Definitive Proxy Statement on Schedule 14A Filed March 15, 2010
File No. 001-02189
Dear Mr. Freyman:
We have reviewed your December 1 0, 2010 response to our November 19, 2010
comment letter and have the following comment. In our comment, we ask you to provide us
with information so we may be tter understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your
response.
After reviewing the information you provide in response to this comment, we may have
additional comments.
Schedule 14A
Executive Compensation
Compensation Discussion and Analysis
Compensation Components
Performance-Based Annual Cash Incentives, page 14
1. Your revised disclosure for 2009 compensa tion provided in response to the prior
comment omits various corporate and individu al goals for each named executive officer
that appear to be material to your compensa tion process. Please pr ovide draft disclosure
of your 2010 compensation that discloses a nd describes all of the corporate and
individual goals for each named executive officer . If you believe that one or more of the
goals that was established and communicated to your named executive officers is not
material, please provide a separate and deta iled analysis for each goal which you believe
is not material that supports your conclusi on that such goal is not material to your
compensation and the process by which you aw ard compensation. Please also confirm
Thomas C. Freyman Abbott Laboratories January 6, 2011 Page 2
that you will disclose in your next proxy statement your Committee’s evaluation of each
goal for each named executive officer.
Please contact Jennifer Riegel at (202 ) 551-3575 or me at (202) 551-3710 with any
questions.
Sincerely,
Jeffrey P. Riedler
Assistant Director