SEC Comment Letter for AMERICAN VANGUARD CORP (AVD) (CIK 0000005981) (AVD) — May 15, 2013
AMERICAN VANGUARD CORP (AVD) (CIK 0000005981)
Date: May 15, 2013 · CIK: 0000005981 · Accession: 0000000000-13-026734
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May 15 , 2013
Via E -mail
David T. Johnson
Chief Financial Officer
American Vanguard Corporation
4695 MacArthur Court
Newport Beach, California 92660
Re: American Vanguard Corporation
Form 10 -K for Fiscal Year Ended December 31, 2011
Filed on March 9, 2012
File No. 001 -13795
Dear Mr. Johnson :
We have completed our review of your filing. We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not asser t staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States. We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be ce rtain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Lyn Shenk
Lyn Shenk
Branch Chief