SEC Comment Letter for Air Products & Chemicals, Inc. (APD) (CIK 0000002969) (APD) — Apr 8, 2011
Air Products & Chemicals, Inc. (APD) (CIK 0000002969)
Date: April 8, 2011 · CIK: 0000002969 · Accession: 0000000000-11-022100
AI Filing Summary & Sentiment
Reasoning
Referenced dates: March 15, 2011, March 28, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE April 8, 2011 Paul E. Huck Senior Vice President and Chief Financial Officer Air Products and Chemicals, Inc. 7201 Hamilton Boulevard Allentown, Pennsylvania 18195-1501 Re: Air Products and Chemicals, Inc. Form 10-K for the Fiscal Year Ended September 30, 2010 Filed November 23, 2010 File No. 1-04534 Response Letter Dated March 28, 2011
Dear Mr. Huck: We have reviewed your response lett er 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 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. General
1. Please refer to comment 3 in our letter dated March 15, 2011. Tell us the dollar amount of revenue you derived from your direct and indirect sales to Sy ria in each of 2008 and 2009, and the dollar amount of any assets and liabilities associated with that country during each of fiscal 2008, 2009, and 2010 . In addition, please discuss the reasons you do not believe your business with Syria is materi al based on qualitative factors. Include discussion of the reasons you do not believe th at your relationship with PetroChina, a company that has been the object of divestme nt and related efforts due to its parent company’s operations in Sudan and Iran, will have a material impact on your reputation and share value. Please contact Pradip Bhaumik, Special Couns el, at (202) 551-3333 or me at (202) 551-
Paul E. Huck Air Products and Chemicals, Inc. April 8, 2011 Page 2 3470 if you have any questions abou t the comment or our review. S i n c e r e l y , C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Pamela Long Assistant Director Division of Cor poration Finance
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
April 8, 2011
Paul E. Huck Senior Vice President and Chief Financial Officer Air Products and Chemicals, Inc. 7201 Hamilton Boulevard Allentown, Pennsylvania 18195-1501
Re: Air Products and Chemicals, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2010
Filed November 23, 2010 File No. 1-04534 Response Letter Dated March 28, 2011
Dear Mr. Huck:
We have reviewed your response lett er 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 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. General
1. Please refer to comment 3 in our letter dated March 15, 2011. Tell us the dollar amount
of revenue you derived from your direct and indirect sales to Sy ria in each of 2008 and
2009, and the dollar amount of any assets and liabilities associated with that country
during each of fiscal 2008, 2009, and 2010 . In addition, please discuss the reasons you
do not believe your business with Syria is materi al based on qualitative factors. Include
discussion of the reasons you do not believe th at your relationship with PetroChina, a
company that has been the object of divestme nt and related efforts due to its parent
company’s operations in Sudan and Iran, will have a material impact on your reputation
and share value. Please contact Pradip Bhaumik, Special Couns el, at (202) 551-3333 or me at (202) 551-
Paul E. Huck
Air Products and Chemicals, Inc. April 8, 2011 Page 2 3470 if you have any questions abou t the comment or our review.
S i n c e r e l y , C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Pamela Long Assistant Director Division of Cor poration Finance