SEC Company Response from STEPAN CO (SCL) (CIK 0000094049) (SCL) — Apr 21, 2005
STEPAN CO (SCL) (CIK 0000094049)
Date: April 21, 2005 · CIK: 0000094049 · Accession: 0001193125-05-081247
AI Filing Summary & Sentiment
Referenced dates: March 18, 2005
Letter
Securities and Exchange Commission Letter VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549-0510 RE: FOIA Confidential Treatment Request Stepan Company Form 10-K for the fiscal year ended December 31, 2004 File No. 1-4462
Dear Mr. Decker:
The following are responses to questions submitted telephonically by Scott Watkinson of the SEC in follow-up to Stepan Company’s written response of April 1, 2005 to the SEC comment letter dated March 18, 2005. Confidential follow-up responses are referenced to the comment numbers in the March 18, 2005 comment letter.
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations:
4. Environmental and Legal Matters, Page 26
Follow-up Question: Could the Company confidentially provide the disaggregated environmental site reserves to facilitate the SEC’s understanding of the Company’s response on April 1?
Response: *
* Confidential treatment requested by Stepan Company. The confidential portion has been so omitted and filed separately with the SEC.
SCL: Page 1 of 2
FOIA Confidential Treatment Requested
Securities and Exchange Commission
CONFIDENTIAL
April 21, 2005
6. Summary of Significant Accounting Policies
Follow-up Question: What are the smaller and more meaningful components of machinery and equipment in dollar terms?
Response:
Machinery and Equipment
$ 621,131
Computer Software and Equipment
30,440
Other (primarily furniture and vehicles)
14,650
Total Machinery and Equipment
$ 666,221
The Company would prefer to continue to present one line item disclosure for all Machinery and Equipment due to the relative small amounts for the additional categories.
If you have any questions or require assistance, please feel free to contact me at (847) 501-2164.
Very truly yours,
James E. Hurlbutt
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CORRESP 1 filename1.htm Securities and Exchange Commission Letter CONFIDENTIAL April 21, 2005 VIA EDGAR Mr. Rufus Decker Accounting Branch Chief Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0510 RE: FOIA Confidential Treatment Request Stepan Company Form 10-K for the fiscal year ended December 31, 2004 File No. 1-4462 Dear Mr. Decker: The following are responses to questions submitted telephonically by Scott Watkinson of the SEC in follow-up to Stepan Company’s written response of April 1, 2005 to the SEC comment letter dated March 18, 2005. Confidential follow-up responses are referenced to the comment numbers in the March 18, 2005 comment letter. Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations: 4. Environmental and Legal Matters, Page 26 Follow-up Question: Could the Company confidentially provide the disaggregated environmental site reserves to facilitate the SEC’s understanding of the Company’s response on April 1? Response: * * Confidential treatment requested by Stepan Company. The confidential portion has been so omitted and filed separately with the SEC. SCL: Page 1 of 2 FOIA Confidential Treatment Requested Securities and Exchange Commission CONFIDENTIAL April 21, 2005 6. Summary of Significant Accounting Policies Follow-up Question: What are the smaller and more meaningful components of machinery and equipment in dollar terms? Response: Machinery and Equipment $ 621,131 Computer Software and Equipment 30,440 Other (primarily furniture and vehicles) 14,650 Total Machinery and Equipment $ 666,221 The Company would prefer to continue to present one line item disclosure for all Machinery and Equipment due to the relative small amounts for the additional categories. If you have any questions or require assistance, please feel free to contact me at (847) 501-2164. Very truly yours, James E. Hurlbutt Vice President - Finance SCL: Page 2 of 2 FOIA Confidential Treatment Requested