SEC Comment Letter for SONOCO PRODUCTS CO (SON) (CIK 0000091767) (SON) — Apr 18, 2008
SONOCO PRODUCTS CO (SON) (CIK 0000091767)
Date: April 18, 2008 · CIK: 0000091767 · Accession: 0000000000-08-020235
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File numbers found in text: 000-00516
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561 April 18, 2008 Mr. Harris E. DeLoach, Jr. Chairman, President and Chief Executive Officer Sonoco Products Company 1 N. Second Street Hartsville, South Carolina 29550
Re: Sonoco Products Company
Form 10-K for Fiscal Year Ended December 31, 2007
Filed February 28, 2008
File No. 000-00516
Dear Mr. DeLoach:
We have reviewed your filing and have th e following comment. Please provide a
written response to our comment. Please be as de tailed as necessary in your explanation.
In our comment, we may ask you to provide us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional
comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K For Fiscal Year Ended December 31, 2007
Note 3. Restructuring and Asset Impairment, page F-7
1. We note that you recognized restructuri ng charges related to the 2006 plan of
$16.8 million during the year ended Decembe r 31, 2007. We also note that you
expect to recognize future additional costs of $2.8 million for the 2006 restructuring plan. Tell us how you determined the period in which the liability will be recognized using the guidance of SFAS 146 paragraph 3.
* * * *
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please furnish a letter that keys your response to our
Mr. Harris E. DeLoach, Jr.
Sonoco Products Company April 18, 2008 Page 2 comment and provides any requested information. Detailed letters gr eatly facilitate our
review. Please understand that we may have additional comments after reviewing your
response to our comment. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Dave Walz at (202) 551-3358 or Nasreen Mohammed at (202)
551-3773 if you have questions regarding comm ents on the financial statements and
related matters. Please contact me at (202) 551-3790 with any other questions.
Sincerely,
Tia Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel and Healthcare Services