SEC Company Response from PLDT Inc. (PHI, PHTCF) (CIK 0000078150) (PHI) — Oct 14, 2014
PLDT Inc. (PHI, PHTCF) (CIK 0000078150)
Date: Oct. 14, 2014 · CIK: 0000078150 · Accession: 0001193125-14-370108
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 30, 2014
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, 2013 filed April 2, 2014, 2006 (File No. 1- 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 September 30, 2014. The comment letter is related to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2013 (the “Form 20-F”), which was filed with the United States Securities and Exchange Commission on April 2, 2014. 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 will provide its response to the Staff’s comments by October 31, 2014.
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) 816-8553 or by e-mail at lrchan@pldt.com.ph, with any questions you may have.
Sincerely,
/s/ Ma. Lourdes C. Rausa-Chan
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CORRESP 1 filename1.htm Correspondence October 14, 2014 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, 2013 filed April 2, 2014, 2006 (File No. 1- 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 September 30, 2014. The comment letter is related to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2013 (the “Form 20-F”), which was filed with the United States Securities and Exchange Commission on April 2, 2014. 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 will provide its response to the Staff’s comments by October 31, 2014. 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) 816-8553 or by e-mail at lrchan@pldt.com.ph, with any questions you may have. Sincerely, /s/ Ma. Lourdes C. Rausa-Chan MA. LOURDES C. RAUSA-CHAN Senior Vice President, Corporate Affairs and Legal Services Head and Corporate Secretary cc: Terry French, Accounting Branch Chief Kathleen Krebs, Special Counsel Christy Adams, Senior Staff Accountant (Securities and Exchange Commission) Napoleon L. Nazareno, President and Chief Executive Officer Anabelle Lim-Chua, Senior Vice President and Treasurer June Cheryl A. Cabal-Revilla, First Vice President and Controller (Philippine Long Distance Telephone Company) Michael G. DeSombre Ram Narayan Paul E. Hubble (Sullivan & Cromwell)