SEC Comment Letter for DANA INC (DAN) (CIK 0000026780) (DAN) — Nov 16, 2012
DANA INC (DAN) (CIK 0000026780)
Date: Nov. 16, 2012 · CIK: 0000026780 · Accession: 0000000000-12-062550
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November 16, 2012 Via E -mail Roger J. Wood President and Chief Executive Officer Dana Holding Corporation 3939 Technology Drive Maumee, OH 43537 Re: Dana Holding Corporation Form 10-K for the Fiscal Year E nded December 31, 2011 Filed February 23, 2012 File No. 001 -01063 Dear Mr. Wood: We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Justin Dobbie Justin Dobbie Legal Branch Chief