SEC Comment Letter for ABBOTT LABORATORIES (ABT) — May 30, 2012
ABBOTT LABORATORIES
Date: May 30, 2012 · CIK: 0000001800 · Accession: 0000000000-12-027934
AI Filing Summary & Sentiment
File numbers found in text: 001-02189
Referenced dates: April 18, 2012
Letter
May 30, 2012 Via E -mail Mr. Thomas C. Freyman Executive Vice President, Finance and Chief Financial Officer Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064 -6400
Re: Abbott Laboratories Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 21, 2012 File No . 001-02189
Dear Mr. Freyman :
We have reviewed your May 2 , 201 2 response to our April 18, 201 2 letter and have the following comment s.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circumstances, please tell us why in you r response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response s to our comment s.
After reviewing the information provide d, we may raise additional comments and/or request that you amend your filing .
Risk Factors
“Other factors can have a material adverse effect on Abbott’s future profitability and financial condition,” page 14
1. We reviewed your response to comment 1 in our letter dated April 18, 2012. In y our response, you note that you depend on well -developed information technology systems to operate your business. In future filings, beginning with your next Form 10 -Q, please provide a separate discussion of the risks posed to your operations from your d ependence upon your technology systems and the risks posed to your business or operations by cyber attacks. If you have experienced any cyber attacks in the past, please state that fact in order to provide the proper context. You may include language tha t indicates that the attacks were mitigated.
Mr. Thomas C. Freyman Abbott Laboratories May 30, 2012 Page 2
Notes to Consolidated Financial Statements Note 1 – Summary of Significant Accounting Policies Concentration of risk and guarantees, page 60
2. As the disclosures requested in prior comment 3 would not substantially duplicat e the disclosures contained in your most recent annual report, we think they should be made when you file your next interim report. Please confirm that the information you intended to include in future Forms 10 -K in response to prior comment 3 will instead be included in your next quarterly report.
3. In your response to prior comment 3 you indicate your belief that separate disclosure by country of your receivables from Spain, Italy, Portugal and Greece is not warranted . As the risks associated with collecting on these receivables are not necessarily the same by country and there is significant disparity in the associated balances by country, we do not agree with your conclusion. P lease confirm that, starting with yo ur next Form 10 -Q, you will disclose the total due and the amount past due for more than a year for each of these countries.
Please contact Ibolya Ignat, Staff Accountant, at (202) 551 -3656 or Mark Brunhofer, Accounting Reviewer, at (202) 551 -3638 if you have questions regarding the processing of your response as well as any questions regarding comments on the financial statements and related matters. You may contact Scot Foley , Staff Attorney, at (202) 551 -3383 or Jennifer Riegel, Special Counsel, at (202) 551 -3575 with questions on any of the other comments. In this regard, do not hesitate to contact me at (202) 551 -3679 .
Sincerely,
/s/ Jim B. Rosenberg
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May 30, 2012 Via E -mail Mr. Thomas C. Freyman Executive Vice President, Finance and Chief Financial Officer Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064 -6400 Re: Abbott Laboratories Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 21, 2012 File No . 001-02189 Dear Mr. Freyman : We have reviewed your May 2 , 201 2 response to our April 18, 201 2 letter and have the following comment s. Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circumstances, please tell us why in you r response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response s to our comment s. After reviewing the information provide d, we may raise additional comments and/or request that you amend your filing . Risk Factors “Other factors can have a material adverse effect on Abbott’s future profitability and financial condition,” page 14 1. We reviewed your response to comment 1 in our letter dated April 18, 2012. In y our response, you note that you depend on well -developed information technology systems to operate your business. In future filings, beginning with your next Form 10 -Q, please provide a separate discussion of the risks posed to your operations from your d ependence upon your technology systems and the risks posed to your business or operations by cyber attacks. If you have experienced any cyber attacks in the past, please state that fact in order to provide the proper context. You may include language tha t indicates that the attacks were mitigated. Mr. Thomas C. Freyman Abbott Laboratories May 30, 2012 Page 2 Notes to Consolidated Financial Statements Note 1 – Summary of Significant Accounting Policies Concentration of risk and guarantees, page 60 2. As the disclosures requested in prior comment 3 would not substantially duplicat e the disclosures contained in your most recent annual report, we think they should be made when you file your next interim report. Please confirm that the information you intended to include in future Forms 10 -K in response to prior comment 3 will instead be included in your next quarterly report. 3. In your response to prior comment 3 you indicate your belief that separate disclosure by country of your receivables from Spain, Italy, Portugal and Greece is not warranted . As the risks associated with collecting on these receivables are not necessarily the same by country and there is significant disparity in the associated balances by country, we do not agree with your conclusion. P lease confirm that, starting with yo ur next Form 10 -Q, you will disclose the total due and the amount past due for more than a year for each of these countries. Please contact Ibolya Ignat, Staff Accountant, at (202) 551 -3656 or Mark Brunhofer, Accounting Reviewer, at (202) 551 -3638 if you have questions regarding the processing of your response as well as any questions regarding comments on the financial statements and related matters. You may contact Scot Foley , Staff Attorney, at (202) 551 -3383 or Jennifer Riegel, Special Counsel, at (202) 551 -3575 with questions on any of the other comments. In this regard, do not hesitate to contact me at (202) 551 -3679 . Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant