SEC Comment Letter for DANA INC (DAN) (CIK 0000026780) (DAN) — Dec 20, 2011
DANA INC (DAN) (CIK 0000026780)
Date: Dec. 20, 2011 · CIK: 0000026780 · Accession: 0000000000-11-072820
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-01063
Referenced dates: December 7, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE December 20, 2011 Via E-mail Mr. James A. Yost Chief Financial Officer Dana Holding Corporation 3939 Technology Drive Maumee, Ohio 43537
Re: Dana Holding Corporation Form 10-K for the year ended December 31, 2010 Filed February 24, 2011 File No. 001-01063
Dear Mr. Yost:
We have reviewed your response letter dated December 7, 2011 and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information. If you do not believe our comment applies to your facts and circumstances please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments.
Annual Report on Form 10-K for the year ended December 31, 2010 Financial Statements, page 37
Notes to Consolidated Financial Statements, page 45 Note 2. Divestitures an d Acquisitions, page 50
1. We note from your response to our prior co mment two that the Structural Products business was not reported as discontinued operations pursuant to the guidance in ASC 205-20-45 due to your significant continuing in volvement with the plant in Longview, Texas. In this regard, please tell us the na ture of the continuing operations in Longview Texas with which the company is involved. Your response should clearly address in detail why the operations at th is plant meet the definition of a continuation of activities under ASC 205-20-20 and why you believe you do not meet the conditions for treatment
Mr. James A. Yost Dana Holding Corporation December 20, 2011 Page 2 as discontinued operations outlined in ASC 205-20-45. We may have further comment upon receipt of your response.
You may contact Heather Cl ark at 202-551-3624 if you ha ve questions regarding comments on the financial statements and rela ted matters. Please contact me at 202-551-3813 with any other questions. Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
December 20, 2011 Via E-mail
Mr. James A. Yost Chief Financial Officer Dana Holding Corporation 3939 Technology Drive Maumee, Ohio 43537
Re: Dana Holding Corporation
Form 10-K for the year ended December 31, 2010
Filed February 24, 2011
File No. 001-01063
Dear Mr. Yost:
We have reviewed your response letter dated December 7, 2011 and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter within ten business days by providing the requested information.
If you do not believe our comment applies to your facts and circumstances please tell us why in your
response.
After reviewing the information you provide in response to this comment, we may have
additional comments.
Annual Report on Form 10-K for the year ended December 31, 2010
Financial Statements, page 37
Notes to Consolidated Financial Statements, page 45
Note 2. Divestitures an d Acquisitions, page 50
1. We note from your response to our prior co mment two that the Structural Products
business was not reported as discontinued operations pursuant to the guidance in ASC
205-20-45 due to your significant continuing in volvement with the plant in Longview,
Texas. In this regard, please tell us the na ture of the continuing operations in Longview
Texas with which the company is involved. Your response should clearly address in
detail why the operations at th is plant meet the definition of a continuation of activities
under ASC 205-20-20 and why you believe you do not meet the conditions for treatment
Mr. James A. Yost
Dana Holding Corporation December 20, 2011 Page 2
as discontinued operations outlined in ASC 205-20-45. We may have further comment
upon receipt of your response.
You may contact Heather Cl ark at 202-551-3624 if you ha ve questions regarding
comments on the financial statements and rela ted matters. Please contact me at 202-551-3813
with any other questions.
Sincerely,
/s/ Linda Cvrkel
Linda Cvrkel Branch Chief