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SEC Company Response from LOWES COMPANIES INC (LOW) (CIK 0000060667) (LOW) — Apr 20, 2005

LOWES COMPANIES INC (LOW) (CIK 0000060667)
Date: April 20, 2005 · CIK: 0000060667 · Accession: 0000060667-05-000103

AI Filing Summary & Sentiment

Referenced dates: April 13, 2005, April 13, 2005

Date
4/13/2005
Author
/s/
Form
CORRESP
Company
LOWES COMPANIES INC (LOW) (CIK 0000060667)

Letter

United States Securities and Exchange Commission Division of Corporate Finance Washington, D.C. 20549-0404 File No. 1-07898

Re: Letter dated April 13, 2005 on Item 4.02 of Form 8-K filed February 23,

Dear Mr. Cash:

Lowe's Companies, Inc. is pleased to respond to the comments of the staff of the Securities and Exchange Commission (the "Commission") regarding our Current Report on Form 8-K filed February 23, 2005. Our responses follow the order in which the staff’s comments were submitted to us in your letter dated April 13, 2005. We first set forth each of your comments as numbered in your letter. We then provide our responses in italics specifically addressing each of your comments.

In connection with our response to the staff’s comments, Lowe’s Companies, Inc. acknowledges the following:

·

We are responsible for the adequacy and accuracy of the disclosure in our filings.

·

The 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.

·

We 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.

If you have any questions or would like to discuss these issues further, please contact us.

Sincerely,
/s/
Kenneth W. Black, Jr.

Show Raw Text
CORRESP
1
filename1.htm

Lowe's Response to SEC Comment Letter 4/13/2005

April 20,
2005

Mr. John
Cash

Accounting
Branch Chief

United
States Securities and Exchange Commission

Division
of Corporate Finance

Washington,
D.C. 20549-0404

Re:
 Letter
dated April 13, 2005 on Item 4.02 of Form 8-K filed February 23,
2005

File No.
1-07898

Dear Mr.
Cash:

Lowe's
Companies, Inc. is pleased to respond to the comments of the staff of the
Securities and Exchange Commission (the "Commission") regarding our Current
Report on Form 8-K filed February 23, 2005.  Our responses follow the order
in which the staff’s comments were submitted to us in your letter dated April
13, 2005.  We first set forth each of your comments as numbered in your
letter.  We then provide our responses in italics specifically addressing
each of your comments.

In
connection with our response to the staff’s comments, Lowe’s Companies, Inc.
acknowledges the following:

    ·

      We
      are responsible for the adequacy and accuracy of the disclosure in our
      filings.

    ·

      The
      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.

    ·

      We
      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.

If you
have any questions or would like to discuss these issues further, please contact
us.

Sincerely,

/s/
Kenneth W. Black, Jr.

Kenneth
W. Black, Jr.

Senior
Vice President and Chief Accounting Officer

Comment
1

Please
amend your report to include the information required by Item 4.02(a)(1) of Form
8-K relating to the date of the conclusion regarding non-reliance on the
financial statements that you have identified.

We
will amend our Form 8-K dated February 23, 2005 to include in our response to
Item 4.02 of Form 8-K the date of our conclusion regarding non-reliance on our
financial statements.

Comment
2

Please
tell us when you intend to file restated financial statements. We may have
further comments after you file the restated financial statements.

We
filed restated financial statements in our Annual Report on Form 10-K for fiscal
2004 that we filed on April 13, 2005. Our Forms 10-Q for fiscal 2005 will
reflect the restated information for the corresponding quarters in fiscal
2004.