SEC Comment Letter for INTEL CORP (INTC) (CIK 0000050863) (INTC) — Mar 31, 2010
INTEL CORP (INTC) (CIK 0000050863)
Date: March 31, 2010 · CIK: 0000050863 · Accession: 0000000000-10-017590
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-06217
Letter
Re: Intel Corporation Form 10-K for the Fiscal Year Ended December 26, 2009 Filed February 22, 2010 File No. 000-06217 Dear Mr. Smith: We have reviewed your filings and have the following comment. Where indicated, we think you should re vise your documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549
DIVISION OF CORPORATION FINANCE
Mail Stop 3030 March 31, 2010 Via U.S. Mail and Fax (408) 765-0766
Mr. Stacy J. Smith Senior Vice President and Chief Financial Officer Intel Corporation 2200 Mission College Boulevard Santa Clara, California 95054
Mr. Stacy J. Smith Intel Corporation March 31, 2010 Page 2 Form 10-K for fiscal year ended December 26, 2009
Exhibits 31.1 and 31.2
1. We note that the certificati ons provided in Exhibits 31.1 and 31.2 contain extraneous language at the top of the page beyond that which is set forth in Item 601(b)(31) of Regulation S-K. In future filings, please pr ovide certifications that do not include the extraneous language.
As appropriate, please respond to this co mment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your response to ou r comment and provides any requested information. Detailed cover le tters greatly facilitate our re view. Please understand that we may have additional comments after revi ewing your amendments and responses to our comments. We urge all persons who are responsi ble for the accuracy an d adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to 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.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
Mr. Stacy J. Smith Intel Corporation March 31, 2010 Page 3 You may contact Julie Sherman at (202) 551-3640 or me at (202) 551-3603 if you have any questions regarding comments on the financial statements and related matters. Please contact Mary Beth Breslin, at (202) 551-3625 or Jay Mumford, Reviewing Attorney, at (202) 551-3637 if you have questions on any other comments. In this regard, do not hesitate to contact Martin James, Seni or Assistant Chief Accountant, at (202) 551- 3671. S i n c e r e l y , J a y W e b b Accounting Reviewer
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3030
March 31, 2010
Via U.S. Mail and Fax (408) 765-0766
Mr. Stacy J. Smith Senior Vice President and Chief Financial Officer Intel Corporation 2200 Mission College Boulevard Santa Clara, California 95054
Re: Intel Corporation
Form 10-K for the Fiscal Year Ended December 26, 2009
Filed February 22, 2010 File No. 000-06217
Dear Mr. Smith:
We have reviewed your filings and have the following comment. Where
indicated, we think you should re vise your documents in response to this comment. If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary. Please be as deta iled as necessary in your explanation. In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure. After reviewing th is information, we may raise additional
comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Stacy J. Smith
Intel Corporation
March 31, 2010 Page 2 Form 10-K for fiscal year ended December 26, 2009
Exhibits 31.1 and 31.2
1. We note that the certificati ons provided in Exhibits 31.1 and 31.2 contain extraneous
language at the top of the page beyond that which is set forth in Item 601(b)(31) of
Regulation S-K. In future filings, please pr ovide certifications that do not include the
extraneous language.
As appropriate, please respond to this co mment within 10 business days or tell us
when you will provide us with a response. Please furnish a cover letter with your response that keys your response to ou r comment and provides any requested
information. Detailed cover le tters greatly facilitate our re view. Please understand that
we may have additional comments after revi ewing your amendments and responses to
our comments. We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to 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.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
Mr. Stacy J. Smith
Intel Corporation March 31, 2010 Page 3
You may contact Julie Sherman at (202) 551-3640 or me at (202) 551-3603 if you
have any questions regarding comments on the financial statements and related matters.
Please contact Mary Beth Breslin, at (202) 551-3625 or Jay Mumford, Reviewing Attorney, at (202) 551-3637 if you have questions on any other comments. In this regard,
do not hesitate to contact Martin James, Seni or Assistant Chief Accountant, at (202) 551-
3671. S i n c e r e l y , J a y W e b b Accounting Reviewer