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SEC Comment Letter for SONOCO PRODUCTS CO (SON) (CIK 0000091767) (SON) — Apr 12, 2011

SONOCO PRODUCTS CO (SON) (CIK 0000091767)
Date: April 12, 2011 · CIK: 0000091767 · Accession: 0000000000-11-022895

AI Filing Summary & Sentiment

File numbers found in text: 000-00516

Date
April 12, 2011
Author
Assistant Director
Form
UPLOAD
Company
SONOCO PRODUCTS CO (SON) (CIK 0000091767)

Letter

April 12, 2011 Via E-Mail H.E. DeLoach, Jr., Chief Executive Officer Sonoco Products Company 1 N. Second St. Hartsville, SC 29550 Re: Sonoco Products Company Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 28, 2011 File No. 000-00516

Dear Mr. DeLoach:

We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments.

Business, page 4

1. We note that sales to Proctor & Gamble repr esent 10% of your consolidated revenues for the fiscal year 2010. Please advise us whet her there are any materi al sales agreements with Proctor & Gamble requiring disclosure under Item 601(b)(10) of Regulation S-K. Exhibits

2. We note that you have omitted various schedul es, exhibits, and/or various attachments from Exhibit 10-13. Please confirm that you wi ll file Exhibit 10-13 in its entirety with your next periodic report.

H.E. DeLoach, Jr. Sonoco Products Company April 12, 2011 Page 2

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of the United States.

You may contact Edwin S. Kim at (202) 551-3297 or Pamela Howell, Special Counsel, at (202) 551-3357 with any questions.

Sincerely,
/ s / P a m e l a H o w e l l f o r John Reynolds
Assistant Director

Show Raw Text
April 12, 2011
 Via E-Mail

H.E. DeLoach, Jr., Chief Executive Officer  Sonoco Products Company  1 N. Second St.  Hartsville, SC 29550
Re: Sonoco Products Company
  Form 10-K for the Fiscal Year Ended December 31, 2010   Filed February 28, 2011
File No. 000-00516

Dear Mr. DeLoach:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Business, page 4

 1. We note that sales to Proctor & Gamble repr esent 10% of your consolidated revenues for
the fiscal year 2010.  Please advise us whet her there are any materi al sales agreements
with Proctor & Gamble requiring disclosure under Item 601(b)(10) of Regulation S-K.
 Exhibits

2. We note that you have omitted various schedul es, exhibits, and/or various attachments
from Exhibit 10-13.  Please confirm that you wi ll file Exhibit 10-13 in  its entirety with
your next periodic report.

H.E. DeLoach, Jr.
Sonoco Products Company  April 12, 2011 Page 2

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Edwin S. Kim at (202) 551-3297 or Pamela Howell, Special Counsel, at
(202) 551-3357 with any questions.

Sincerely,
         / s /  P a m e l a  H o w e l l          f o r           John Reynolds
Assistant Director