SEC Company Response from CLOROX (CLX) — Apr 29, 2005
CLOROX CO /DE/ (CLX) (CIK 0000021076)
Date: April 29, 2005 · CIK: 0000021076 · Accession: 0001193125-05-089940
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File numbers found in text: 333-123115
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CORRESP 1 filename1.htm Acceleration Request THE CLOROX COMPANY 1221 Broadway Oakland, California 94612-1888 April 29, 2005 Via Facsimile and EDGAR Transmission Securities and Exchange Commission Division of Corporation Finance Judiciary Plaza, 450 Fifth Street, N.W. Mail Stop 0306 Washington, D.C. 20549-0305 Attention: Edward M. Kelly, Esq. Re: The Clorox Company Registration Statement on Form S-4 (No. 333-123115) Dear Mr. Kelly: Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request acceleration of the effective time of the above-referenced Registration Statement of The Clorox Company (the “Company”), so that it may become effective at 4:00 p.m., Washington, D.C. time, as of the date hereof, or as soon as possible thereafter. Furthermore, we hereby acknowledge that: (1) should the U.S. Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy or accuracy of the disclosure in the filing; and (3) the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Sincerely, THE CLOROX COMPANY By: /s/ Laura Stein Laura Stein Senior Vice President—General Counsel