SEC Comment Letter for ABBOTT LABORATORIES (ABT) — Dec 28, 2012
ABBOTT LABORATORIES
Date: Dec. 28, 2012 · CIK: 0000001800 · Accession: 0000000000-12-069769
AI Filing Summary & Sentiment
File numbers found in text: 001-02189
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December 28, 2012
Via E -mail
Mr. Thomas C. Freyman
Executive Vice President , Finance and Chief Financial Officer
Abbott Laboratories
100 Abbott Park
Abbott Park, IL 60064
Re: Abbott Laboratories
Item 4.01 Form 8-K dated December 14, 2012
Filed December 20, 2012
File No. 001-02189
Dear Mr. Freyman :
We have reviewed your filing and have the following comment s. In our comment s, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within five business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requ ested
response. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response. Please furnish us a
letter on EDGAR under the form type label CORRESP that key s your responses to our
comments.
After reviewing any amendment to your filing and any information you provide in
response to the comment s, we may have additional comments.
1. Please confirm that you will amend this Item 4.01 8 -K to:
Disclose the effective da te of the dismissal of Deloitte & Touche LLP once they have
completed their audit services for the fiscal year ending December 31, 2012 and the
filing of the Company’s 2012 annual report on Form 10 -K; and
Update the interim period related to paragraphs (a) (1)(iv) and (a)(2) of Item 304 of
Regulation S -K through the effective date of dismissal.
2. Regarding your disclosure under paragraph (b) Newly Appointed Independent Registered
Public Accountant, you indicate that Ernst & Young LLP will perform audit servic es
beginning with the fiscal year ending December 31, 2014. Please confirm that December
31, 2014 is the correct audit period ending and, if so, please tell us who will perform
audit services beginning with the fiscal year ending December 31, 2013 and wher e the
related disclosures have been provided. If the audit period ending was incorrectly
presented, please tell us the correct date and revise in your amended filing.
Mr. Thomas C. Freyman
Abbott Laboratories
December 2 8, 2012
Page 2
3. Upon amending your filing, please include, as Exhibit 16, an updated letter from your
former accountants, Deloitte & Touche, LLP, addressing t he revised 8 -K disclosure , as
required by Item 304(a)(3) of Regulation S -K.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that th e filing include s all information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accur acy
and adequacy of the disclosures they have made.
In responding t o our comment s, please provide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
the staff comment s or changes to disclosu re in response to staff comment s do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert the staff comment s as a defense in any proceeding initiated
by the Commi ssion or any person under the federal securities laws of the United States.
You may contact Sasha Parikh, Staff Accountant, at (202) 551 -3627 if you have questions
regarding the comment s. 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