SEC Comment Letter for LEGGETT & PLATT INC (LEG) (CIK 0000058492) (LEG) — Apr 13, 2005
LEGGETT & PLATT INC (LEG) (CIK 0000058492)
Date: April 13, 2005 · CIK: 0000058492 · Accession: 0000000000-05-017920
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File numbers found in text: 333-123213
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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
April 13, 2005
By facsimile to (314) 259-2020 and U.S. Mail
Ernest C. Jett, Esq.
Senior Vice President, General Counsel and Secretary
Leggett & Platt, Incorporated
No. 1 Leggett Road
Carthage, MO 64836
RE: Leggett & Platt, Incorporated.
Pre-effective Amendment 1 to Registration Statement on Form
S-3
Filed April 7, 2005
File No. 333-123213
Dear Mr. Jett:
We reviewed the filing and have the comment below.
1. Refer to prior comment 8. Revise these disclosures that can
be
read to imply that investors do not have rights under the federal
securities laws about the disclosures in the prospectus:
* The third sentence in the second paragraph under "Description of
Capital Stock" on page 21.
* The third sentence in the fifth paragraph under "Preferred Share
Purchase Rights and Series A Junior Participating Preferred Stock"
on
page 26.
* The third sentence in the second paragraph under "Certain
Charter
and Bylaw Provisions" on page 26.
Closing
File an amendment to the S-3 in response to the comment. To
expedite our review, you may wish to provide us three marked
courtesy
copies of the amendment. Include with the filing any supplemental
information requested and a cover letter tagged as correspondence
that keys the responses to the comment. If you think that
compliance
with the comment is inappropriate, provide the basis in the
letter.
We may have additional comments after review of the amendment, the
response to the comment, and any supplemental information.
You may direct questions on comments and other disclosure
issues to Edward M. Kelly, Senior Counsel, at (202) 942-1978 or me
at
(202) 942-2864.
Very truly yours,
Jennifer R. Hardy
Legal
Branch Chief
cc: R. Randall Wang, Esq.
William L. Cole, Esq.
1 Metropolitan Square, Suite 3600
St. Louis, MO 63102
John W. White, Esq.
Cravath, Swaine & Moore LLP
Worldwide Plaza
825 8th Avenue
New York, NY 10019
Ernest C. Jett, Esq.
April 13, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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