SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for ABBOTT LABORATORIES (ABT) — Apr 12, 2016

ABBOTT LABORATORIES
Date: April 12, 2016 · CIK: 0000001800 · Accession: 0000000000-16-071826

AI Filing Summary & Sentiment

Date
April 12, 2016
Author
/s/ Suzanne Hayes
Form
UPLOAD
Company
ABBOTT LABORATORIES

Letter

Mail Stop 4720 April 12, 2016 Via E -mail Hubert L. Allen Executive Vice President, General Counsel and Secretary Abbott Laboratories Dept. 0364, Bldg. AP6D -2 100 Abbott Park Road Abbott Park, IL 60604

Re: Abbott Laboratories Annual Report on Form 10-K Filed February 19, 2016 File No. 001 -02189

Dear Mr. Allen :

We have reviewed your filing an d have the following comment . Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances , please tell us why in a response.

After reviewing your response to this comment, we may have additional comments.

Risk Factors “Fluctuation in foreign currency exchange rates may adversely affect our financial statements . . .,” page 13

1. We note that sales in international markets comprised 70 % of your consolidated net sales in 2015. Additionally, we note that in Mr. White’s March 2, 2016 letter to shareholders he noted that the strong U.S. dollar was the primary factor in your business environment and accounted for an 8.3% reduction of your to p line. Given the significant impact of foreign exchange rates, please consider expanding this risk factor to include more information about the impact of foreign exchange rates and how these rates have impacted your financial results.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its manageme nt are

Hubert L. Allen Abbott Laboratories April 12, 2016 Page 2

in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In responding to our comment, 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;

 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 comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact S cot Foley at (202) 551 -3383 or me at (202) 551 -3675 with any questio ns.

Sincerely,
/s/ Suzanne Hayes

Show Raw Text
Mail Stop 4720

April 12, 2016

Via E -mail
Hubert L. Allen
Executive Vice President, General Counsel and Secretary
Abbott Laboratories
Dept. 0364, Bldg.  AP6D -2
100 Abbott Park Road
Abbott Park, IL 60604

Re: Abbott Laboratories
 Annual Report on Form 10-K
Filed February 19, 2016
File No. 001 -02189

Dear Mr. Allen :

We have reviewed your filing an d have the following comment . Please respond to these
comments  within ten busine ss days by providing the requested information or advis e us as soon
as possible when you will respond.  If you  do not believe our comment appl ies to your facts and
circumstances , please tell us why in a response.

After reviewing your response to this comment, we may have  additional comments.

Risk Factors
“Fluctuation in foreign currency exchange rates may adversely affect our financial statements . .
.,” page 13

1.  We note that sales in international markets comprised 70 % of your consolidated net sales
in 2015.  Additionally, we note that in Mr. White’s March 2, 2016 letter to shareholders
he noted that the strong U.S. dollar was the primary factor in your business environment
and accounted for an 8.3% reduction of your to p line. Given the significant impact of
foreign exchange rates, please consider expanding this risk factor to include more
information about the impact of foreign exchange rates and how these rates have
impacted your financial results.

We urge all persons  who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its manageme nt are

Hubert L. Allen
Abbott Laboratories
April 12, 2016
Page 2

 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comment, 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;

 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 comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact S cot Foley  at (202) 551 -3383  or me at (202) 551 -3675  with any questio ns.

Sincerely,

 /s/ Suzanne Hayes

Suzanne Hayes
Assistant Director