SEC Company Response from MEDTRONIC INC (CIK 0000064670) — Jan 18, 2005

MEDTRONIC INC (CIK 0000064670)
Date: Jan. 18, 2005 · CIK: 0000064670 · Accession: 0000950134-05-000853

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AI Filing Summary & Sentiment

File numbers found in text: 333-121239

Referenced dates: December 23, 2004

Date

January 18, 2005

Author

Not clearly detected

Form

CORRESP

Company

MEDTRONIC INC (CIK 0000064670)

Letter

Division of Corporate Finance Securities and Exchange Commission Medtronic, Inc. Registration Statement on Form S-4 File No. 333-121239 Acceleration Request

Re:

Dear Mr. Buchmiller:

Medtronic, Inc. requests acceleration of the effective date of the above-referenced Registration Statement so that the same shall become effective as of 11:00 a.m. Eastern Standard Time on Wednesday, January 19, 2005, or as soon thereafter as possible.

In accordance with the Commission’s letter dated December 23, 2004, the Company hereby acknowledges that:

• Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• The Company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
MEDTRONIC, INC.

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CORRESP
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corresp

January 18, 2005

BY FACSIMILE

Mr. Tim Buchmiller

Division of Corporate Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, DC 20549

    Re:

    Medtronic, Inc.

    Registration Statement on Form S-4

    File No. 333-121239

Acceleration Request

Dear Mr. Buchmiller:

     Medtronic, Inc. requests acceleration of the effective date of the
above-referenced Registration Statement so that the same shall become effective
as of 11:00 a.m. Eastern Standard Time on Wednesday, January 19, 2005, or as
soon thereafter as possible.

     In accordance with the Commission’s letter dated December 23, 2004, the Company
hereby acknowledges that:

    •
    Should the Commission or the staff, acting pursuant to
delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the
filing;

    •
    The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and

    •
    The Company may not assert this action as defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

    Very truly yours,

MEDTRONIC, INC.

    By /s/ Robert L. Ryan

    Robert L. Ryan

    Senior Vice President and Chief Financial Officer

SecProbe.io