SEC Comment Letter for ECOLAB INC. (ECL) (CIK 0000031462) (ECL) — Apr 7, 2009
ECOLAB INC. (ECL) (CIK 0000031462)
Date: April 7, 2009 · CIK: 0000031462 · Accession: 0000000000-09-018105
AI Filing Summary & Sentiment
Reasoning
Referenced dates: March 19, 2009, March 31, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0510 DIVISION OF CORPORATION FINANCE Mail Stop 7010 April 7, 2009 By U.S. Mail and Facsimile Lawrence T. Bell General Counsel Ecolab Inc. 370 Wabasha Street North St. Paul, Minnesota 55102 Re: Ecolab Inc. Form 10-K for Fiscal Year Ended December 31, 2007 Proxy Statement on Schedule 14A Filed on March 19, 2008 File No. 1-09328
Dear Mr. Bell: We have reviewed your response letter dated March 31, 2009 and have the following additional comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. We welcome any questions you may have about our comments or on any other aspect of our review. Definitive Proxy Statement on Schedule 14A
Compensation Discussion & Analysis, page 27
1. We note your response to comment 1 from our letter dated March 19, 2009 and reissue this comment. In this regard, we are requesting disclosure which describes the nature of the individual performance goals similar to the disclosure in your March 31, 2009 response letter to us. Note that we are not asking you to quantify these qualitative goals. Please confirm that in future filings, you will disclose the nature of the individual performance goals for each of your named executive officers who have such goals.
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter on EDGAR that keys your responses to our comments and provides any requested supplemental information. Detailed
Lawrence T. Bell Ecolab Inc. April 7, 2009 Page 2 response letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. Please direct questions to Sherry Haywood, Staff Attorney at (202) 551-3345, or me at (202) 551-3760. Sincerely,
Pamela Long Assistant Director cc: Sarah Z. Erickson (v ia facsimile 651/ 293-2573) Associate General Counsel Ecolab Inc.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
April 7, 2009
By U.S. Mail and Facsimile
Lawrence T. Bell General Counsel Ecolab Inc. 370 Wabasha Street North St. Paul, Minnesota 55102
Re: Ecolab Inc.
Form 10-K for Fiscal Year Ended
December 31, 2007
Proxy Statement on Schedule 14A Filed on March 19, 2008 File No. 1-09328
Dear Mr. Bell:
We have reviewed your response letter dated March 31, 2009 and have the following
additional comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. We welcome any questions you may have about our comments or on any other aspect of our review.
Definitive Proxy Statement on Schedule 14A
Compensation Discussion & Analysis, page 27
1. We note your response to comment 1 from our letter dated March 19, 2009 and reissue
this comment. In this regard, we are requesting disclosure which describes the nature of the individual performance goals similar to the disclosure in your March 31, 2009 response letter to us. Note that we are not asking you to quantify these qualitative goals. Please confirm that in future filings, you will disclose the nature of the individual performance goals for each of your named executive officers who have such goals.
As appropriate, please respond to these comments within 10 business days or tell us
when you will provide us with a response. Please furnish a letter on EDGAR that keys your responses to our comments and provides any requested supplemental information. Detailed
Lawrence T. Bell
Ecolab Inc. April 7, 2009 Page 2 response letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
Please direct questions to Sherry Haywood, Staff Attorney at (202) 551-3345, or me at
(202) 551-3760.
Sincerely,
Pamela Long Assistant Director
cc: Sarah Z. Erickson (v ia facsimile 651/ 293-2573)
Associate General Counsel Ecolab Inc.