SEC Company Response from PLDT Inc. (PHI, PHTCF) (CIK 0000078150) (PHI) — Jul 25, 2012
PLDT Inc. (PHI, PHTCF) (CIK 0000078150)
Date: July 25, 2012 · CIK: 0000078150 · Accession: 0001193125-12-313277
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-03006
Referenced dates: July 12, 2012
Letter
Via EDGAR Division of Corporation Finance Securities and Exchange Commission United States of America Re: Philippine Long Distance Telephone Company Annual Report on Form 20-F for the Fiscal Year ended December 31, 2011 filed on March 28, 2012 (File No. 001-03006)
Dear Mr. Spirgel:
Philippine Long Distance Telephone Company (the “Company”) has received a comment letter from the staff of the Division of Corporation Finance (the “Staff”), dated July 12, 2012. The comment letter is related to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2011 (the “Form 20-F”), which was filed with the United States Securities and Exchange Commission on March 28, 2012. We wish to thank you and the other members of the Staff for providing us with your comments.
The Company notes that the Staff has requested that the Company either (i) respond to the Staff’s comments within 10 business days or (ii) inform the Staff as to when the Company will provide a response to the comments. The Company has carefully reviewed and considered the Staff’s comments and is in the process of preparing a response to the comments. The Company contacted Ms. Leigh Ann Schultz over the phone on July 24, 2012 to discuss the time extension to file its response to the comment letter. Based on that discussion, the Staff has preliminarily agreed to extend the time to respond to the Staff’s comments to August 9, 2012.
Thank you again for your time. Please feel free to contact Michael G. DeSombre of Sullivan & Cromwell (tel: (+852) 2826-8696; fax: (+852) 2826-1774; e-mail: desombrem@sullcrom.com), or the undersigned by phone at (+632) 816-8534 or by e-mail at jcfurigay@pldt.com.ph, with any questions you may have.
Mr. Larry Spirgel
- -
Sincerely,
/s/ June Cheryl Cabal-Revilla
Show Raw Text
CORRESP 1 filename1.htm Correspondence July 25, 2012 Via EDGAR Mr. Larry Spirgel Assistant Director Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 United States of America Re: Philippine Long Distance Telephone Company Annual Report on Form 20-F for the Fiscal Year ended December 31, 2011 filed on March 28, 2012 (File No. 001-03006) Dear Mr. Spirgel: Philippine Long Distance Telephone Company (the “Company”) has received a comment letter from the staff of the Division of Corporation Finance (the “Staff”), dated July 12, 2012. The comment letter is related to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2011 (the “Form 20-F”), which was filed with the United States Securities and Exchange Commission on March 28, 2012. We wish to thank you and the other members of the Staff for providing us with your comments. The Company notes that the Staff has requested that the Company either (i) respond to the Staff’s comments within 10 business days or (ii) inform the Staff as to when the Company will provide a response to the comments. The Company has carefully reviewed and considered the Staff’s comments and is in the process of preparing a response to the comments. The Company contacted Ms. Leigh Ann Schultz over the phone on July 24, 2012 to discuss the time extension to file its response to the comment letter. Based on that discussion, the Staff has preliminarily agreed to extend the time to respond to the Staff’s comments to August 9, 2012. Thank you again for your time. Please feel free to contact Michael G. DeSombre of Sullivan & Cromwell (tel: (+852) 2826-8696; fax: (+852) 2826-1774; e-mail: desombrem@sullcrom.com), or the undersigned by phone at (+632) 816-8534 or by e-mail at jcfurigay@pldt.com.ph, with any questions you may have. Mr. Larry Spirgel - 2 - Sincerely, /s/ June Cheryl Cabal-Revilla June Cheryl Cabal-Revilla First Vice President and Controller cc: Terry French, Accounting Branch Chief Leigh Ann Schultz (Securities and Exchange Commission) Napoleon L. Nazareno, President and Chief Executive Officer Anabelle Lim-Chua, Senior Vice President and Treasurer Ma. Lourdes C. Rausa-Chan, Senior Vice President and Corporate Secretary (Philippine Long Distance Telephone Company) Michael G. DeSombre Frank Yihe Jin Jingqiu (Joseph) Mei (Sullivan & Cromwell)