SEC Comment Letter for JOHNSON & JOHNSON (JNJ) (CIK 0000200406) (JNJ) — Jun 17, 2014
JOHNSON & JOHNSON (JNJ) (CIK 0000200406)
Date: June 17, 2014 · CIK: 0000200406 · Accession: 0000000000-14-030658
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File numbers found in text: 001-03215
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June 16, 2014 Via E-mail Mr. Dominic J. Caruso Chief Financial Officer Johnson & Johnson One Johnson & Johnson Plaza New Brunswick, NJ 08933 Re: Johnson & Johnson Form 10-K for the Fiscal Year Ended December 31, 2013 Filed February 21, 2014 File No . 001-03215 Dear Mr. Caruso: We have reviewed your May 1 4, 201 4 response to our May 2, 2014 letter and have the following comment. Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe the comment appl ies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment. After reviewing any information you provide in response to the comment , we may have additional comments. Exhibit 13 Notes to Consolidated Financial Statements 19. Selected Quarterly Financial Data, page 50 1. Your response to comment 2 did not fully explain how you determined the pre -tax amount required to be recognized in eac h quarter and why such amounts were not required to be recognized in an earlier period. Please p rovide to us your computation of the pre -tax amounts included in the total net litigation expense of $391 million, $308 million, $720 million and $227 million i n each of the four quarters in 2013 disaggregated by matter. Tell us the pre -tax amount that was recorded in each quarter of all years related to each product liability matter with charges recognized in 2013, that is, the timeline of accounting for expens e recognized for each major product liability matter with expenses in 2013. Tell us if you recognized any product liability expenses in the first quarter of 2014. Mr. Dominic J. Caruso Johnson & Johnson June 16, 201 4 Page 2 You may contact Christine Allen Torney , Staff Accountant , at (202) 551 -3652 or Lisa Vanjos ke, Assistant Chief Accountant, at (202) 551 -3614 if you have questions regarding the comment . In this regard, do not hesitate to contact me at (202) 551 -3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant