SEC Comment Letter for TEREX CORP (TEX) (CIK 0000097216) (TEX) — Dec 7, 2012
TEREX CORP (TEX) (CIK 0000097216)
Date: Dec. 7, 2012 · CIK: 0000097216 · Accession: 0000000000-12-065987
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 5, 2012, November 20, 2012
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE December 6, 2012 Via E -mail 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, 2011 Filed February 29, 2012 File No. 1 -10702 Response Letter Dated December 5, 2012
Dear Mr. DeFeo:
We have reviewed your response letter and have the following comment.
Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, we may have additional comments.
General
1. You state in response to comment 1 in our letter dated November 20, 2012 that certain of your foreign subsidiaries have s old foreign -manufactured equipment containing less than 10% U.S. content into Iran, Sudan, and Syria. Please describe to us the types of equipment sold into those countries.
Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202 ) 551 -3470 if you have any questions about the comment or our review.
Sincerely,
/s/ Cecilia Blye
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
December 6, 2012
Via E -mail
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, 2011
Filed February 29, 2012
File No. 1 -10702
Response Letter Dated December 5, 2012
Dear Mr. DeFeo:
We have reviewed your response letter and have the following comment.
Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing the information you provide in response to this comment, we may have
additional comments.
General
1. You state in response to comment 1 in our letter dated November 20, 2012 that certain of
your foreign subsidiaries have s old foreign -manufactured equipment containing less than
10% U.S. content into Iran, Sudan, and Syria. Please describe to us the types of
equipment sold into those countries.
Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202 ) 551 -3470 if
you have any questions about the comment or our review.
Sincerely,
/s/ Cecilia Blye
Cecilia Blye, Chief
Office of Global Security Risk
Ronald M. DeFeo
Terex Corporation
December 6, 2012
Page 2
cc: Amanda Ravitz
Assistant Director
Division of Corporation Finance