SEC Company Response from CORNING (GLW) — Jun 23, 2009
CORNING INC /NY (GLW) (CIK 0000024741)
Date: June 23, 2009 · CIK: 0000024741 · Accession: 0000947871-09-000454
AI Filing Summary & Sentiment
Referenced dates: June 9, 2009
Letter
Re:
[Letterhead of Corning Incorporated]
June 23,
Securities and Exchange Commission
450 Fifth Street, N.W., Stop 4-5
Washington, D.C. 20549
Form 10-K for the fiscal year ended December 31,
File No. 1-3247
Ladies and Gentlemen:
As requested by the staff (the “Staff”) of the Securities and Exchange Commission in its letter dated June 9, 2009 to Mr. James B. Flaws of Corning Incorporated, we hereby advise the Staff that as of December 31, 2008, the amount of precious metals with indefinite useful lives that was included as “Equipment” in the “Property, Net of Accumulated Depreciation” line in our Consolidated Balance Sheet was approximately $**CONFIDENTIAL TREATMENT REQUESTED BY CORNING INCORPORATED PURSUANT TO RULE 83**. For reference, as disclosed in footnote 8 to the Consolidated Financial Statements included in our Annual Report on Form 10-K for the year ended December 31, 2008, the “Equipment” balance as of such date was $8.4 billion.
Corning acknowledges that:
·
We are responsible for the adequacy and accuracy of the disclosure in our filings;
·
Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
·
We may not assert Staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.
* * * * *
Please direct accounting questions regarding this response to me at (607) 974-7674. Please direct any questions on other issues to R. Tony Tripeny, Senior Vice President and Corporate Controller at (607) 974-3331.
Sincerely,
/s/ Phillip E. Gorham
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CORRESP
1
filename1.htm
[Letterhead
of Corning Incorporated]
June 23,
2009
Securities
and Exchange Commission
450 Fifth
Street, N.W., Stop 4-5
Washington,
D.C. 20549
Re:
Form
10-K for the fiscal year ended December 31,
2008
File
No. 1-3247
Ladies
and Gentlemen:
As
requested by the staff (the “Staff”) of the Securities and Exchange Commission
in its letter dated June 9, 2009 to Mr. James B. Flaws of Corning Incorporated,
we hereby advise the Staff that as of December 31, 2008, the amount of precious
metals with indefinite useful lives that was included as “Equipment” in the
“Property, Net of Accumulated Depreciation” line in our Consolidated Balance
Sheet was approximately $**CONFIDENTIAL TREATMENT REQUESTED BY
CORNING INCORPORATED PURSUANT TO RULE 83**. For reference, as disclosed
in footnote 8 to the Consolidated Financial Statements included in our Annual
Report on Form 10-K for the year ended December 31, 2008, the “Equipment”
balance as of such date was $8.4 billion.
Corning
acknowledges that:
·
We
are responsible for the adequacy and accuracy of the disclosure in our
filings;
·
Staff
comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the
filing; and
·
We
may not assert Staff comments as a defense in any proceedings initiated by
the Commission or any person under the federal securities laws of the
United States.
* * * * *
Please
direct accounting questions regarding this response to me at (607)
974-7674. Please direct any questions on other issues to R. Tony
Tripeny, Senior Vice President and Corporate Controller at (607)
974-3331.
Sincerely,
/s/ Phillip E. Gorham
Phillip
E. Gorham
Assistant
Controller
cc:
Wendell
P. Weeks, Chairman and Chief Executive
Officer
James B.
Flaws, Vice Chairman and Chief Financial Officer
Vincent
P. Hatton, Sr. Vice President & General Counsel
R. Tony
Tripeny, Sr. Vice President & Corporate Controller
Kurt M.
Landgraf, Chairman, Corning Board of Directors Audit Committee
Mike
Thiessen, PricewaterhouseCoopers LLP
Stephen
T. Giove, Shearman & Sterling