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SEC Comment Letter for SMITHFIELD FOODS INC (SFD) (CIK 0000091388) (SFD) — Mar 16, 2012

SMITHFIELD FOODS INC (SFD) (CIK 0000091388)
Date: March 16, 2012 · CIK: 0000091388 · Accession: 0000000000-12-013559

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File numbers found in text: 001-15321

Date
March 16, 2012
Author
Linda Cvrkel
Form
UPLOAD
Company
SMITHFIELD FOODS INC (SFD) (CIK 0000091388)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE March 16, 2012 Via E-mail Mr. Robert W. Manly, IV Chief Financial Officer Smithfield Foods, Inc. 200 Commerce Street Smithfield, Virginia 23430

Re: Smithfield Foods, Inc. Form 10-K for the fiscal year ended May 1, 2011 Filed June 17, 2011 Form 10-Q for the fiscal quarter ended October 30, 2011 Filed December 9, 2011 File No. 001-15321

Dear Mr. Manly: We have completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

        March 16, 2012
Via E-mail

Mr. Robert W. Manly, IV Chief Financial Officer Smithfield Foods, Inc. 200 Commerce Street Smithfield, Virginia 23430

Re: Smithfield Foods, Inc.
 Form 10-K for the fiscal year ended May 1, 2011
Filed June 17, 2011 Form 10-Q for the fiscal quarter ended October 30, 2011 Filed December 9, 2011
 File No. 001-15321

Dear Mr. Manly:
 We have completed our review of your f ilings.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or the filings and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,  /s/ Linda Cvrkel  Linda Cvrkel Branch Chief