SEC Company Response from KYOCERA CORP (CIK 0000057083) — Apr 25, 2005
KYOCERA CORP (CIK 0000057083)
Date: April 25, 2005 · CIK: 0000057083 · Accession: 0001193125-05-083240
AI Filing Summary & Sentiment
File numbers found in text: 001-07952
Referenced dates: April 13, 2005, April 6, 2005, February 3, 2005
Letter
Via Edgar Office of the Chief Accountant, Division of Corporation Finance, Securities and Exchange Commission Kyocera Corporation Annual Report on Form 20-F for the year ended March 31, 2004 File No. 001-07952
Re:
Dear Ms. Tillan:
In response to the comments of the staff of the Securities and Exchange Commission in your letter dated April 13, 2005 with respect to our letter dated April 6, 2005, which set forth our responses to the staff’s previous comments on the annual report on Form 20-F of Kyocera Corporation (“Kyocera”) for the year ended March 31, 2004 in your letter dated February 3, 2005, we provide the following response.
With respect to the above-referenced comments of the staff and responses of Kyocera, Kyocera acknowledges that:
•
Kyocera 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 filings; and
•
Kyocera 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.
Please contact the undersigned, Shoichi Aoki, or our legal counsel, Sullivan & Cromwell LLP, if you have any questions.
Sincerely,
/s/ Shoichi Aoki
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CORRESP 1 filename1.htm Correspondence Letter April 25, 2005 Via Edgar Ms. Kate Tillan Office of the Chief Accountant, Division of Corporation Finance, Securities and Exchange Commission Washington, DC 20549-0305 U.S.A. Re: Kyocera Corporation Annual Report on Form 20-F for the year ended March 31, 2004 File No. 001-07952 Dear Ms. Tillan: In response to the comments of the staff of the Securities and Exchange Commission in your letter dated April 13, 2005 with respect to our letter dated April 6, 2005, which set forth our responses to the staff’s previous comments on the annual report on Form 20-F of Kyocera Corporation (“Kyocera”) for the year ended March 31, 2004 in your letter dated February 3, 2005, we provide the following response. With respect to the above-referenced comments of the staff and responses of Kyocera, Kyocera acknowledges that: • Kyocera 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 filings; and • Kyocera 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. 1 Please contact the undersigned, Shoichi Aoki, or our legal counsel, Sullivan & Cromwell LLP, if you have any questions. Sincerely, /s/ Shoichi Aoki Shoichi Aoki General manager of Financial and Accounting Department Kyocera Corporation Tel: +81-75-604-3500 Fax: +81-75-604-3557 CC: Mr. Daniel Gordon Mr. Tom Dyer Office of Chief Accountant, Division of Corporation Finance, Securities and Exchanged Commission Mr. Izumi Akai, Esq. Sullivan & Cromwell LLP Tel: +81-3-3213-6145 Fax: +81-3-3213-6470 Mr. Yukihiro Matsunaga Partner, ChuoAoyama PricewaterhouseCoopers Tel: +81-75-241-1945 Mr. Paul Bruner Partner, PricewaterhouseCoopers Tel: +61-2-8266-4664 Mr. Dennis Neider Partner, PricewaterhouseCoopers L.L.P. Tel: +1-973-236-4996 2