SEC Comment Letter for Lumen Technologies, (LUMN) — May 27, 2010
Lumen Technologies, Inc.
Date: May 27, 2010 · CIK: 0000018926 · Accession: 0000000000-10-029556
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-7784
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 May 27, 2010 Via U.S. Mail and Facsimile (318-362-1683) Mr. Glen F. Post, III Chief Executive Officer and President CenturyLink, Inc. 100 CenturyLink Dr. Monroe, LA 71203 RE: CenturyLink, Inc. (f/k/a CenturyTel, Inc.) Form 10-K for the fiscal year ended Decemb er 31, 2009 Filed March 1, 2010 File No. 001-7784
Dear Mr. Post: We have reviewed your filing and have the following comment. If you disagree with our comment, we will consider your explan ation as to why it is inapplicable or a revision is unnecessary. Pleas e be as detailed as necessa ry in your explanation. Please comply with our comment in futu re filings. Confirm in writing that you intend to do so within the tim e frame set forth below.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Glen F. Post, III CenturyLink, Inc. May 27, 2010 Page 2 Definitive Proxy Statement filed on April 7, 2010
Risk Oversight, page 20
1. We note your disclosure rela ted to the board’s leader ship structure and risk oversight in response to Item 407(h) of Re gulation S-K. In future filings, please also discuss the effect that the board’s ro le in the risk overs ight of the company has on the board’s leadership structure.
* * * * Please respond to this comment thr ough correspondence over EDGAR within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested information. Detail letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that the company is responsible for the adequacy and accuracy of the disclosure in the filings; staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not fo reclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
Mr. Glen F. Post, III CenturyLink, Inc. May 27, 2010 Page 3 Please contact Jay Knight, Attorney -Adviser, at (202) 551-3370, Robert Bartelmes, Senior Financial Analyst, at (202) 551-3354, or me at (202) 551-3810 with any questions. S i n c e r e l y , / s / R o b e r t B a r t e l m e s
for Larry Spirgel A s s i s t a n t D i r e c t o r
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
May 27, 2010
Via U.S. Mail and Facsimile (318-362-1683)
Mr. Glen F. Post, III Chief Executive Officer and President CenturyLink, Inc. 100 CenturyLink Dr. Monroe, LA 71203
RE: CenturyLink, Inc. (f/k/a CenturyTel, Inc.)
Form 10-K for the fiscal year ended Decemb er 31, 2009
Filed March 1, 2010
File No. 001-7784
Dear Mr. Post:
We have reviewed your filing and have the following comment. If you disagree
with our comment, we will consider your explan ation as to why it is inapplicable or a
revision is unnecessary. Pleas e be as detailed as necessa ry in your explanation.
Please comply with our comment in futu re filings. Confirm in writing that you
intend to do so within the tim e frame set forth below.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Glen F. Post, III
CenturyLink, Inc. May 27, 2010 Page 2 Definitive Proxy Statement filed on April 7, 2010
Risk Oversight, page 20
1. We note your disclosure rela ted to the board’s leader ship structure and risk
oversight in response to Item 407(h) of Re gulation S-K. In future filings, please
also discuss the effect that the board’s ro le in the risk overs ight of the company
has on the board’s leadership structure.
* * * *
Please respond to this comment thr ough correspondence over EDGAR within 10
business days or tell us when you will provide us with a response. Please furnish a letter
that keys your response to our comment and provides any requested information. Detail
letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that
the company is responsible for the adequacy and accuracy of the disclosure in the
filings;
staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not fo reclose the Commission from taking any
action with respect to the filing; and
the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
Mr. Glen F. Post, III
CenturyLink, Inc. May 27, 2010 Page 3
Please contact Jay Knight, Attorney -Adviser, at (202) 551-3370, Robert
Bartelmes, Senior Financial Analyst, at (202) 551-3354, or me at (202) 551-3810 with
any questions. S i n c e r e l y , / s / R o b e r t B a r t e l m e s
for Larry Spirgel
A s s i s t a n t D i r e c t o r