SEC Comment Letter for DANA INC (DAN) (CIK 0000026780) (DAN) — Jun 28, 2010
DANA INC (DAN) (CIK 0000026780)
Date: June 28, 2010 · CIK: 0000026780 · Accession: 0000000000-10-036086
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 30, 2010
Letter
Mail Stop 3561 June 28, 2010 Via Fax & U.S. Mail Mr. James E. Sweetnam Chief Executive Officer Dana Holding Corporation 3939 Technology Drive Maumee, Ohio 43537
Re: Dana Holding Corporation Form 10-K for the year ended December 31, 2009 Filed February 24, 2010 File No. 1-01063
Dear Mr. Sweetnam:
We have received your letter dated May 27, 2 010, in response to our letter dated April 30, 2010, and have the following additional comment. Please respond to confirm that such comment will be complied with in future filings. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond within ten (10) business days.
Definitive Proxy Statement on Schedule 14A
Compensation Discussion and Analysis, page 10 Administration, page 10
1. While we note your response to our prior comment 17, it appears that you are using survey data in your compensati on decisions. For guidance refer to Compliance and Disclosure Interpretation 118.05 of Regulation S-K. In future filings please list the companies to whic h you benchmark and disclose the degree to which the Compensation Committee consid ered such companies comparable to you or please advise. Refer to Item 402(b)(2)(xiv) of Regulation S-K.
Mr. James E. Sweetnam Dana Holding Corporation June 28, 2010 Page 2 You may contact Effie Simpson at (202) 551-3346, or the und ersigned at (202) 551-3750 if you have questions regarding comm ents on the financial statements and related matters. Please contact Julie Be ll at (202) 551-3574 with any other questions.
Sincerely,
Linda Cvrkel Branch Chief
Via Fax: James A. Yost, CFO
(419) 887-5200
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Mail Stop 3561 June 28, 2010 Via Fax & U.S. Mail Mr. James E. Sweetnam Chief Executive Officer Dana Holding Corporation 3939 Technology Drive Maumee, Ohio 43537 Re: Dana Holding Corporation Form 10-K for the year ended December 31, 2009 Filed February 24, 2010 File No. 1-01063 Dear Mr. Sweetnam: We have received your letter dated May 27, 2 010, in response to our letter dated April 30, 2010, and have the following additional comment. Please respond to confirm that such comment will be complied with in future filings. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond within ten (10) business days. Definitive Proxy Statement on Schedule 14A Compensation Discussion and Analysis, page 10 Administration, page 10 1. While we note your response to our prior comment 17, it appears that you are using survey data in your compensati on decisions. For guidance refer to Compliance and Disclosure Interpretation 118.05 of Regulation S-K. In future filings please list the companies to whic h you benchmark and disclose the degree to which the Compensation Committee consid ered such companies comparable to you or please advise. Refer to Item 402(b)(2)(xiv) of Regulation S-K. Mr. James E. Sweetnam Dana Holding Corporation June 28, 2010 Page 2 You may contact Effie Simpson at (202) 551-3346, or the und ersigned at (202) 551-3750 if you have questions regarding comm ents on the financial statements and related matters. Please contact Julie Be ll at (202) 551-3574 with any other questions. Sincerely, Linda Cvrkel Branch Chief Via Fax: James A. Yost, CFO (419) 887-5200