SEC Comment Letter for ABBOTT LABORATORIES (ABT) — Sep 2, 2011
ABBOTT LABORATORIES
Date: Sept. 2, 2011 · CIK: 0000001800 · Accession: 0000000000-11-052897
AI Filing Summary & Sentiment
File numbers found in text: 001-02189
Letter
September 2, 2011 Via E-mail Mr. Miles White Chairman and Chief Executive Officer Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064-6400
Re: Abbott Laboratories Form 10-K for the Year Ended December 31, 2010 Filed February 18, 2011 File No. 001-02189
Dear Mr. White:
We have reviewed your August 22, 2011 res ponses to our July 25, 2011 comments and have the following comment. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provid e the requested response. Please furnish us a letter on EDGAR under the form type label CORRE SP that keys your response to our comment.
After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
Results of Operations
Research and Development Programs, page 38
1. We have reviewed the information provided in your response to prior comment one. We acknowledge that you are unable to predict whether and, if so, when your phase III products will be approved and therefore canno t disclose the precise number of years you will have the exclusive rights to them. Howe ver, we believe, based on the information provided in your response, that disclosure of certain of the information you provided would be meaningful. More sp ecifically, information that provides a floor and ceiling of exclusivity and how that floor and ceiling may be effected by future delays in the approval process, would appear to be useful. For exampl e, you may disclose the timing of expiration for significant patents that you believe provide exclus ivity for each project in phase III, without indica ting the name or other identifying information about the patent, and may provide other exclusivity periods indicating wh ether, under what conditions and to what extent these other excl usivity periods would be available for that product. Please provide us pr oposed disclosure to be includ ed in future periodic reports for each of your products in phase III.
Mr. Miles White Abbott Laboratories September 2, 2011 Page 2
Please contact Kei Nakada, Staff Accountan t, at (202) 551-3659 or Gus Rodriguez, Accounting Branch Chief, at (202) 551-3752, if you have questions regarding the comment. In this regard, do not hesitate to contact me at (202) 551-3679.
Sincerely,
/ s / J i m B . R o s e n b e r g
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September 2, 2011
Via E-mail
Mr. Miles White
Chairman and Chief Executive Officer
Abbott Laboratories
100 Abbott Park Road
Abbott Park, Illinois 60064-6400
Re: Abbott Laboratories
Form 10-K for the Year Ended December 31, 2010
Filed February 18, 2011
File No. 001-02189
Dear Mr. White:
We have reviewed your August 22, 2011 res ponses to our July 25, 2011 comments and
have the following comment.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provid e the requested response. Please furnish us a
letter on EDGAR under the form type label CORRE SP that keys your response to our comment.
After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.
Results of Operations
Research and Development Programs, page 38
1. We have reviewed the information provided in your response to prior comment one. We
acknowledge that you are unable to predict whether and, if so, when your phase III
products will be approved and therefore canno t disclose the precise number of years you
will have the exclusive rights to them. Howe ver, we believe, based on the information
provided in your response, that disclosure of certain of the information you provided
would be meaningful. More sp ecifically, information that provides a floor and ceiling of
exclusivity and how that floor and ceiling may be effected by future delays in the
approval process, would appear to be useful. For exampl e, you may disclose the timing
of expiration for significant patents that you believe provide exclus ivity for each project
in phase III, without indica ting the name or other identifying information about the
patent, and may provide other exclusivity periods indicating wh ether, under what
conditions and to what extent these other excl usivity periods would be available for that
product. Please provide us pr oposed disclosure to be includ ed in future periodic reports
for each of your products in phase III.
Mr. Miles White
Abbott Laboratories
September 2, 2011
Page 2
Please contact Kei Nakada, Staff Accountan t, at (202) 551-3659 or Gus Rodriguez,
Accounting Branch Chief, at (202) 551-3752, if you have questions regarding the comment. In
this regard, do not hesitate to contact me at (202) 551-3679.
Sincerely,
/ s / J i m B . R o s e n b e r g
Jim B. Rosenberg Senior Assistant Chief Accountant