SEC Comment Letter for OMNICOM GROUP INC. (OMC) (CIK 0000029989) (OMC) — Jan 18, 2008
OMNICOM GROUP INC. (OMC) (CIK 0000029989)
Date: Jan. 18, 2008 · CIK: 0000029989 · Accession: 0000000000-08-003443
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-10551
Referenced dates: December 14, 2007, September 27, 2007
Letter
Re: Omnicom Group Inc. Definitive Schedule 14A Filed April 23, 2007 File No. 001-10551 Dear Mr. O’Brien: We have reviewed your response letter dated December 14, 2007 and have the following comment. Please respond to our comment by February 1, 2008, or tell us by that time when you will provide us with a re sponse. If the comment requests revised disclosure in future filings, please confir m in writing that you will comply with the comments in your future filings and also ex plain to us how you intend to comply. We welcome any questions you may have about our comments or any other aspect of our review.
January 18, 2008 Mail Stop 3720 By U.S. Mail and facsimile to (212) 415-3574
Michael J. O’Brien Senior Vice President, Gene ral Counsel and Secretary Omnicom Group Inc. 437 Madison Avenue New York, NY 10022
Compensation Discussion and Analysis, page 5
Annual Performance-Based Compensation Awards, page 7 1. We have considered your response to co mment six in our letter dated September 27, 2007. Please provide a more comprehensiv e analysis as to why disclosure of each performance target would cause you competitive harm. Your response should be a thorough and detailed analysis focusing on the specific facts and circumstances of your business and targets. You should address separately each performance target you used and explain how disclosure could lead to competitive harm.
Mr. Michael J. O’Brien Omnicom Group Inc. January 18, 2008 Page 2 Please contact me at (202) 551-3350 with any questions. S i n c e r e l y , K a t h l e e n K r e b s S p e c i a l C o u n s e l cc: By facsimile to (202) 637-2201 Joel H. Trotter Latham & Watkins LLP
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January 18, 2008
Mail Stop 3720
By U.S. Mail and facsimile to (212) 415-3574
Michael J. O’Brien
Senior Vice President, Gene ral Counsel and Secretary
Omnicom Group Inc. 437 Madison Avenue New York, NY 10022
Re: Omnicom Group Inc.
Definitive Schedule 14A Filed April 23, 2007
File No. 001-10551
Dear Mr. O’Brien:
We have reviewed your response letter dated December 14, 2007 and have the
following comment. Please respond to our comment by February 1, 2008, or tell us by
that time when you will provide us with a re sponse. If the comment requests revised
disclosure in future filings, please confir m in writing that you will comply with the
comments in your future filings and also ex plain to us how you intend to comply. We
welcome any questions you may have about our comments or any other aspect of our review.
Compensation Discussion and Analysis, page 5
Annual Performance-Based Compensation Awards, page 7
1. We have considered your response to co mment six in our letter dated September
27, 2007. Please provide a more comprehensiv e analysis as to why disclosure of
each performance target would cause you competitive harm. Your response
should be a thorough and detailed analysis focusing on the specific facts and circumstances of your business and targets. You should address separately each
performance target you used and explain how disclosure could lead to competitive
harm.
Mr. Michael J. O’Brien
Omnicom Group Inc. January 18, 2008 Page 2
Please contact me at (202) 551-3350 with any questions.
S i n c e r e l y , K a t h l e e n K r e b s S p e c i a l C o u n s e l cc: By facsimile to (202) 637-2201
Joel H. Trotter Latham & Watkins LLP