SEC Comment Letter for TEREX CORP (TEX) (CIK 0000097216) (TEX) — Jul 26, 2018
TEREX CORP (TEX) (CIK 0000097216)
Date: July 26, 2018 · CIK: 0000097216 · Accession: 0000000000-18-023032
AI Filing Summary & Sentiment
Reasoning
Letter
Re: Terex Corporation Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 16 , 2018 File No. 1-10702 Dear Mr. Garrison : We have limited our review of your filing to your contacts with a country that has been identified as a state sponsor of terrorism, and we have the following comment. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. At this juncture, we are asking you to provide us with information so w e may better understand your disclosure.
July 26 , 2018
Via E -mail John L. Garrison, Jr. Chairman and Chief Executive Officer Terex Corporation 200 Nyala Farm Road Westport, Connecticut 06880
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 fact s 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. In your letter to us dated July 14, 2015, you stated that you had sold equipmen t into Syria, and that you may continue to have such sales to that country. As you know, Syria is designated by the State Department as a state sponsor of terrorism, and is subject to U.S. economic sanctions and export controls. You do not include disclo sure about Syria in the Form 10 -K. Please describe to us the nature and extent of your past, current and anticipated contacts with Syria since your 2015 letter, including contacts with its government, whether through subsidiaries, dealers, distributors, o r other direct or indirect arrangements.
John L. Garrison, Jr. Terex Corporation July 26 , 2018 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contac t 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
July 26 , 2018
Via E -mail
John L. Garrison, Jr.
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, 2017
Filed February 16 , 2018
File No. 1-10702
Dear Mr. Garrison :
We have limited our review of your filing to your contacts with a country that has been
identified as a state sponsor of terrorism, and we have the following comment. Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues. At this juncture, we are asking you to provide us with information so w e may
better understand your disclosure.
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 fact s 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. In your letter to us dated July 14, 2015, you stated that you had sold equipmen t into
Syria, and that you may continue to have such sales to that country. As you know, Syria
is designated by the State Department as a state sponsor of terrorism, and is subject to
U.S. economic sanctions and export controls. You do not include disclo sure about Syria
in the Form 10 -K. Please describe to us the nature and extent of your past, current and
anticipated contacts with Syria since your 2015 letter, including contacts with its
government, whether through subsidiaries, dealers, distributors, o r other direct or indirect
arrangements.
John L. Garrison, Jr.
Terex Corporation
July 26 , 2018
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contac t 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
cc: Amanda Ravitz
Assistant Director
Division of Corporation Finance