SEC Comment Letter for MITSUI & CO LTD (CIK 0000067099) — Jan 3, 2005
MITSUI & CO LTD (CIK 0000067099)
Date: Jan. 3, 2005 · CIK: 0000067099 · Accession: 0000000000-05-000259
AI Filing Summary & Sentiment
Letter
Mail Stop 05-07 December 28, 2004 Via U.S. Mail Shoei Utsuda President and Chief Executive Officer Mitsui & Co. Ltd. 2-1, Ohtemachi 1-Chome, Chiyoda-Ku, Tokyo 100-0004, Japan
RE: Mitsui & Co. Ltd. Form 20-F for the year ended March 31, 2004 File No. 0-09929
Dear Mr. Utsuda:
We have limited our review of your Form 20-F to disclosures relating to your contacts with countries that have been identified as state sponsors of terrorism, and will make no further review of the Form 20-F. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. At this juncture, we are asking you to provide us with supplemental information, so that we may better understand your disclosure. Please be as detailed as necessary in your response. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 20-F for fiscal year ended 3/31/04
General
We note from the list of subsidiaries filed as Exhibit 8.1 that the Company has an Iranian subsidiary, Mitsui & Co., Iran Ltd. In light of the fact that Iran has been identified by the U.S. State Department as a state sponsor of terrorism, and is subject to economic sanctions administered by the U.S. Treasury Department`s Office of Foreign Assets Control, please advise us of the materiality to the Company of its operations in Iran, and give us your view as to whether those operations constitute a material investment risk for your security holders. In preparing your response, please consider that evaluations of materiality should not be based solely on quantitative factors, but should include consideration of all factors that a reasonable investor would deem important in making an investment decision. Closing
Please understand that we may have additional comments after we review your response to our comment. You may contact me at (202) 942-7817 if you have any questions about the comment or our review.
Sincerely,
Cecilia Blye, Chief
Office of Global Security
Risk
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<TYPE>LETTER
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<TEXT>
Mail Stop 05-07
December 28, 2004
Via U.S. Mail
Shoei Utsuda
President and Chief Executive Officer
Mitsui & Co. Ltd.
2-1, Ohtemachi 1-Chome,
Chiyoda-Ku, Tokyo 100-0004, Japan
RE: Mitsui & Co. Ltd.
Form 20-F for the year ended March 31, 2004
File No. 0-09929
Dear Mr. Utsuda:
We have limited our review of your Form 20-F to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 20-F. Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues. At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure. Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 20-F for fiscal year ended 3/31/04
General
We note from the list of subsidiaries filed as Exhibit 8.1 that
the
Company has an Iranian subsidiary, Mitsui & Co., Iran Ltd. In
light
of the fact that Iran has been identified by the U.S. State
Department as a state sponsor of terrorism, and is subject to
economic sanctions administered by the U.S. Treasury Department`s
Office of Foreign Assets Control, please advise us of the
materiality
to the Company of its operations in Iran, and give us your view as
to
whether those operations constitute a material investment risk for
your security holders. In preparing your response, please
consider
that evaluations of materiality should not be based solely on
quantitative factors, but should include consideration of all
factors
that a reasonable investor would deem important in making an
investment decision.
Closing
Please understand that we may have additional comments after
we
review your response to our comment. You may contact me at (202)
942-7817 if you have any questions about the comment or our
review.
Sincerely,
Cecilia Blye, Chief
Office of Global Security
Risk
cc: Roger Schwall
Assistant Director
Division of Corporation Finance
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Shoei Utsuda
Mitsui & Co. Ltd.
December 28, 2004
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404
DIVISION OF
CORPORATION FINANCE
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