SEC Comment Letter for OMNICOM GROUP INC. (OMC) (CIK 0000029989) (OMC) — Mar 4, 2008
OMNICOM GROUP INC. (OMC) (CIK 0000029989)
Date: March 4, 2008 · CIK: 0000029989 · Accession: 0000000000-08-011325
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-10551
Letter
Re: Omnicom Group Inc. Definitive Schedule 14A Filed April 23, 2007 File No. 001-10551 Dear Mr. O’Brien: We have reviewed your February 29, 2008 response to our comments of January 18, 2008. Without more detail, we cannot agre e or disagree with your conclusion that you have an appropriate basis to omit the iden tified performance targets. Since you are in possession of all of the facts related to your di sclosure, we have decided that we have no basis to disagree with your decision to omit th is information from your filing. As in all cases, we remind you that you are responsible for the adequacy and accuracy of the disclosure in your filings. We do not have any further comments on your filing.
March 4, 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
If you have any further questions regardi ng our review of your filing, please call me at (202) 551-3350.
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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March 4, 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 February 29, 2008 response to our comments of January
18, 2008. Without more detail, we cannot agre e or disagree with your conclusion that
you have an appropriate basis to omit the iden tified performance targets. Since you are in
possession of all of the facts related to your di sclosure, we have decided that we have no
basis to disagree with your decision to omit th is information from your filing. As in all
cases, we remind you that you are responsible for the adequacy and accuracy of the
disclosure in your filings. We do not have any further comments on your filing.
If you have any further questions regardi ng our review of your filing, please call
me at (202) 551-3350.
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