SEC Comment Letter for BRISTOL MYERS SQUIBB CO (BMY, BMYMP, CELG-RI) (CIK 0000014272) (BMY) — Mar 30, 2005
BRISTOL MYERS SQUIBB CO (BMY, BMYMP, CELG-RI) (CIK 0000014272)
Date: March 30, 2005 · CIK: 0000014272 · Accession: 0000000000-05-015098
AI Filing Summary & Sentiment
Letter
March 25, 2005 Via U.S. Mail Peter R. Dolan Chief Executive Officer Bristol-Myers Squibb Company 345 Park Avenue New York, N.Y. 10154
RE: Bristol-Myers Squibb Company Form 10-K for the fiscal year ended December 31, 2004 File No. 1-1136
Dear Mr. Dolan:
We have limited our review of your Form 10-K to disclosures relating to your contacts with countries that have been identified as state sponsors of terrorism, and will make no further review of the Form 10-K. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. At this juncture, we are asking you to provide us with supplemental information, so that we may better understand your disclosure. Please be as detailed as necessary in your response. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General -
We note that in Exhibit 21 to the Company`s 10-K for the fiscal year ended December 31, 2004, the Company lists as subsidiaries Bristol Iran Private Company Limited, Bristol (Iran) S.A., BMS Pharmaceutical Korea B.V. and BMS Pharmaceutical Korea Limited.
In light of the fact that Iran and North Korea have been identified by the U.S. State Department as state sponsors of terrorism, and are subject to economic sanctions administered by the U.S. Treasury Department`s Office of Foreign Assets Control, please describe for us the extent of the Company`s operations in Iran and, if applicable, North Korea; the materiality to the Company of its operations in each country; and your view as to whether those operations, individually or in the aggregate, constitute a material investment risk for your security holders. In preparing your response please consider that evaluations of materiality should not be based solely on quantitative factors, but should include consideration of all factors, including the potential impact of corporate activities upon a company`s reputation and share value, that a reasonable investor would deem important in making an investment decision.
Closing
Please understand that we may have additional comments after we review your response to our comment. Please contact Jack Guggenheim at (202) 942-7896 if you have any questions about the comment or our review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
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<DOCUMENT>
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<TEXT>
March 25, 2005
Via U.S. Mail
Peter R. Dolan
Chief Executive Officer
Bristol-Myers Squibb Company
345 Park Avenue
New York, N.Y. 10154
RE: Bristol-Myers Squibb Company
Form 10-K for the fiscal year ended December 31, 2004
File No. 1-1136
Dear Mr. Dolan:
We have limited our review of your Form 10-K to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 10-K. Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues. At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure. Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
General -
We note that in Exhibit 21 to the Company`s 10-K for the fiscal
year
ended December 31, 2004, the Company lists as subsidiaries Bristol
Iran Private Company Limited, Bristol (Iran) S.A., BMS
Pharmaceutical
Korea B.V. and BMS Pharmaceutical Korea Limited.
In light of the fact that Iran and North Korea have been
identified
by the U.S. State Department as state sponsors of terrorism, and
are
subject to economic sanctions administered by the U.S. Treasury
Department`s Office of Foreign Assets Control, please describe for
us
the extent of the Company`s operations in Iran and, if applicable,
North Korea; the materiality to the Company of its operations in
each
country; and your view as to whether those operations,
individually
or in the aggregate, constitute a material investment risk for
your
security holders. In preparing your response please consider that
evaluations of materiality should not be based solely on
quantitative
factors, but should include consideration of all factors,
including
the potential impact of corporate activities upon a company`s
reputation and share value, that a reasonable investor would deem
important in making an investment decision.
Closing
Please understand that we may have additional comments after
we
review your response to our comment. Please contact Jack
Guggenheim
at (202) 942-7896 if you have any questions about the comment or
our
review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Jeffrey Riedler
Assistant Director
Division of Corporation Finance
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