SEC Comment Letter for TEREX CORP (TEX) (CIK 0000097216) (TEX) — Jul 21, 2009
TEREX CORP (TEX) (CIK 0000097216)
Date: July 21, 2009 · CIK: 0000097216 · Accession: 0000000000-09-038789
AI Filing Summary & Sentiment
Reasoning
Referenced dates: July 17, 2009, June 25, 2009
Letter
Re: Terex Corporation Form 10-K for the Fiscal Year Ended December 31, 2008 Filed February 27, 2009 File No. 1-10702 Response Letter Dated July 17, 2009 Dear Mr. DeFeo:
July 21, 2009 Via U.S. Mail and Facsimile (203-222-7976)
Ronald M. DeFeo Chairman and Chief Executive Officer Terex Corporation 200 Nyala Farm Road Westport, Connecticut 06880
We have reviewed your response letter dated July 17, 2009, and we have the following comment. We welcome any questi ons you may have about our comment or on any other aspect of our review. Feel fr ee to call us at the telephone numbers listed at the end of this letter. General
1. We note your response to comment 2 of our letter dated June 25, 2009. You discuss qualitative materiality in terms of the legality of your activities in countries identified as state sponsors of terrorism. However, the investor sentiment referenced in our comment does not turn on the legality of contacts with those countries. Please expand your discussion to address materiality in light of the referenced investor sentiment notwithstanding the legality of your contacts with Iran, Sudan and Syria.
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Please respond to this comment within 10 business days or tell us when you will provide us with a response. Pleas e submit your response letter on EDGAR.
Please understand that we may have addi tional comments after we review your response to our comment. Pl ease contact Pradip Bhaumik, Special Counsel, at (202) 551- 3333 if you have any questions about the commen t or our review. You may also contact me at (202) 551-3470. S i n c e r e l y ,
Ronald M. DeFeo Terex Corporation July 21, 2009 Page 2 C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Peggy Fisher Assistant Director Division of Corporation Finance
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July 21, 2009 Via U.S. Mail and Facsimile (203-222-7976) Ronald M. DeFeo Chairman and Chief Executive Officer Terex Corporation 200 Nyala Farm Road Westport, Connecticut 06880 Re: Terex Corporation Form 10-K for the Fiscal Year Ended December 31, 2008 Filed February 27, 2009 File No. 1-10702 Response Letter Dated July 17, 2009 Dear Mr. DeFeo: We have reviewed your response letter dated July 17, 2009, and we have the following comment. We welcome any questi ons you may have about our comment or on any other aspect of our review. Feel fr ee to call us at the telephone numbers listed at the end of this letter. General 1. We note your response to comment 2 of our letter dated June 25, 2009. You discuss qualitative materiality in terms of the legality of your activities in countries identified as state sponsors of terrorism. However, the investor sentiment referenced in our comment does not turn on the legality of contacts with those countries. Please expand your discussion to address materiality in light of the referenced investor sentiment notwithstanding the legality of your contacts with Iran, Sudan and Syria. * * * * * Please respond to this comment within 10 business days or tell us when you will provide us with a response. Pleas e submit your response letter on EDGAR. Please understand that we may have addi tional comments after we review your response to our comment. Pl ease contact Pradip Bhaumik, Special Counsel, at (202) 551- 3333 if you have any questions about the commen t or our review. You may also contact me at (202) 551-3470. S i n c e r e l y , Ronald M. DeFeo Terex Corporation July 21, 2009 Page 2 C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Peggy Fisher Assistant Director Division of Corporation Finance