SEC Company Response from SMITHFIELD FOODS INC (SFD) (CIK 0000091388) (SFD) — Jan 16, 2007
SMITHFIELD FOODS INC (SFD) (CIK 0000091388)
Date: Jan. 16, 2007 · CIK: 0000091388 · Accession: 0001193125-07-006762
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-138090
Letter
Re: Smithfield Foods, Inc.
Acceleration request
VIA EDGAR AND FACSIMILE
January 16, 2007
Amendment No. 3 to Registration Statement on Form S-4
Filed January 16, 2007
File No. 333-138090
Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attention: Max A. Webb
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Smithfield Foods, Inc. (the “Registrant”) hereby requests acceleration of the effectiveness of the above-referenced Registration Statement on Form S-4, as amended by Amendment No. 1, Amendment No. 2 and Amendment No. 3 thereto, so that it will become effective at 4:00 p.m. Eastern time on January 17, 2007 or as soon thereafter as is practicable. The Registrant hereby acknowledges the following: (i) should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare this filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Registrant 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.
Securities and Exchange Commission
Attention Mr. Max A. Webb
Page 2 of 2
Very truly yours,
SMITHFIELD FOODS, INC.
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CORRESP 1 filename1.htm Acceleration request VIA EDGAR AND FACSIMILE January 16, 2007 Re: Smithfield Foods, Inc. Amendment No. 3 to Registration Statement on Form S-4 Filed January 16, 2007 File No. 333-138090 Securities and Exchange Commission Division of Corporate Finance 100 F. Street, N.E. Washington, D.C. 20549 Attention: Max A. Webb Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Smithfield Foods, Inc. (the “Registrant”) hereby requests acceleration of the effectiveness of the above-referenced Registration Statement on Form S-4, as amended by Amendment No. 1, Amendment No. 2 and Amendment No. 3 thereto, so that it will become effective at 4:00 p.m. Eastern time on January 17, 2007 or as soon thereafter as is practicable. The Registrant hereby acknowledges the following: (i) should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare this filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Registrant 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. Securities and Exchange Commission Attention Mr. Max A. Webb Page 2 of 2 Very truly yours, SMITHFIELD FOODS, INC. By: /s/ Jeffrey A. Deel Name: Jeffrey A. Deel Title: Corporate Controller cc: Maripat Alpuche Simpson Thacher & Bartlett LLP Robert E. Spatt, Esq. Simpson Thacher & Bartlett LLP Michael H. Cole, Esq. Smithfield Foods, Inc. Rolaine Bancroft Securities and Exchange Commission Jean Yu Securities and Exchange Commission Linda Cvrkel Securities and Exchange Commission