SEC Company Response from CHIQUITA BRANDS INTERNATIONAL INC (CIK 0000101063) — Nov 2, 2005
CHIQUITA BRANDS INTERNATIONAL INC (CIK 0000101063)
Date: Nov. 2, 2005 · CIK: 0000101063 · Accession: 0001193125-05-214221
AI Filing Summary & Sentiment
File numbers found in text: 333-123181, 333-128162
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission File No. 333-128162 Form 10-Q for the quarter ended June 30, 2005 Filed August 5, 2005 File No. 1-1550
Dear Ms. Kramer:
We have reviewed the comment contained in your letter of October 31, 2005 addressed to Mr. Brian W. Kocher, regarding the subject filings. For ease of reference, your comment is provided in bold below, and our response to the comment is provided in normal type.
Controls and Procedures, page 24
Changes in Internal Control Over Financial Reporting, page 24
1. We note your response to prior comment 1. Confirm that you will not include such qualifications in future filings and that you will describe any changes, as required by Item 308(c) of Regulation S-K. Also, we direct you to Question and Answer 5 of the Management’s Report on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports Frequently Asked Questions (October 6, 2004) available on our website at http://www.sec.gov/info/accountants/controlfaq1004.htm.
We will modify our disclosures in future filings to describe affirmatively any changes during the applicable reporting period that materially affected, or are reasonably likely to materially affect, our internal control over financial reporting, as required by Item 308(c) of Regulation S-K. Furthermore, we will not include any qualifications to our disclosures regarding material changes in internal control over financial reporting.
250 East Fifth Street, Cincinnati, Ohio 45202
(513) 784-8577
E-Mail: bkocher@chiquita.com
If you have further comments or questions related to internal control matters or disclosures, please direct them to the undersigned. Any other comments or questions should be directed to Robert W. Olson, Esq., Senior Vice President, General Counsel and Secretary. Mr. Olson can be contacted at the Company’s address or by phone at 513-784-8804.
Sincerely,
/s/ Brian W. Kocher
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SEC Response Letter
BRIAN W. KOCHER
Vice President, Controller and Chief Accounting Officer
November 2, 2005
VIA EDGAR
Ms. Melinda Kramer
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W, Mail Stop 04-05.
Washington, D.C. 20545
Re:
Chiquita Brands International, Inc.
Amendment
No. 1 to Registration Statement on Form S-3
Filed September 7, 2005
File No. 333-123181
Registration Statement on Form S-4
Filed September 7, 2005
File No. 333-128162
Form 10-Q
for the quarter ended June 30, 2005
Filed August 5, 2005
File No. 1-1550
Dear Ms. Kramer:
We have reviewed the comment contained in your letter of October 31, 2005 addressed to Mr. Brian W. Kocher, regarding the subject filings. For ease of reference, your comment is provided in bold below,
and our response to the comment is provided in normal type.
Controls and
Procedures, page 24
Changes in
Internal Control Over Financial Reporting, page 24
1.
We note your response to prior comment 1. Confirm that you will not include such qualifications in future filings and that you will describe any changes, as required by
Item 308(c) of Regulation S-K. Also, we direct you to Question and Answer 5 of the Management’s Report on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports Frequently Asked Questions
(October 6, 2004) available on our website at http://www.sec.gov/info/accountants/controlfaq1004.htm.
We will modify our disclosures in future filings to describe affirmatively any changes during the applicable reporting period that materially affected,
or are reasonably likely to materially affect, our internal control over financial reporting, as required by Item 308(c) of Regulation S-K. Furthermore, we will not include any qualifications to our disclosures regarding material changes in
internal control over financial reporting.
250 East Fifth
Street, Cincinnati, Ohio 45202
(513) 784-8577
E-Mail: bkocher@chiquita.com
If you have further comments or questions related to internal control matters or disclosures, please direct them to the
undersigned. Any other comments or questions should be directed to Robert W. Olson, Esq., Senior Vice President, General Counsel and Secretary. Mr. Olson can be contacted at the Company’s address or by phone at 513-784-8804.
Sincerely,
/s/ Brian W. Kocher
Brian W. Kocher
Vice President, Controller and
Chief Accounting Officer
cc:
T. Richter
Fernando Aguirre
Jeffrey M. Zalla
Robert W. Olson