SEC Company Response from JOHNSON & JOHNSON (JNJ) (CIK 0000200406) (JNJ) — Feb 14, 2008
JOHNSON & JOHNSON (JNJ) (CIK 0000200406)
Date: Feb. 14, 2008 · CIK: 0000200406 · Accession: 0000200406-08-000044
AI Filing Summary & Sentiment
File numbers found in text: 001-03215
Referenced dates: November 29, 2007
Letter
Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 Re: Letter dated November 29, 2007 Regarding Definitive Proxy Statement Filed March 14, 2007 (File No. 001-03215)
Dear Mr. Buchmiller:
The following sets forth the responses of Johnson & Johnson (the “Company”) to the comments on the above referenced proxy statement in your letter of November 29, 2007 to our Chairman and Chief Executive Officer, Mr. William C. Weldon. For you convenience, we have included your comments with the letter. Our responses use the same numbering as your letter.
Annual Performance Bonus. page 18
Comment 1: We note from your response to prior comment 5 that you may omit specific targets or performance objectives in your future filings if you believe it is appropriate to do so. If the specific targets or performance objectives that you may omit in future filings are similar to the targets or objectives that you omitted in your definitive proxy statement filed on March 14, 2007, please provide us with a detailed explanation supporting your conclusion that disclosure of those targets or objectives would result in competitive harm such that the information could be excluded under Instruction 4 to Item 402(b) of Regulation S-K.
Response: The Company notes the staff’s comment. If the specific targets or performance objectives for 2007 disclosed in its 2008 Proxy Statement are similar to the specific targets or objectives that the Company omitted in its March 14, 2007 Proxy Statement and are material, then the Company will disclose those 2007 targets and objectives in its 2008 Proxy Statement.
2006 Bonus and Long-Term Incentive Awards…, page 22
Comment 2: It is not clear from your response to prior comment 6 that you will identify the companies in your financial peer group in your future filings. Please tell us whether you will identify the companies in your financial peer group in future filings.
Response: The Company notes the staff’s comment. The Company will identify the companies in its 2007 financial peer groups in its 2008 Proxy Statement.
If you have any questions or comments, please call Douglas Chia, Senior Counsel and Assistant Corporate Secretary at 732-524-3292 or me at 732-524-2452.
Very
truly yours,
/s/
Steven M. Rosenberg
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CORRESP
1
filename1.htm
correspondence.htm
STEVEN
M. ROSENBERG
SECRETARY
ASSISTANT
GENERAL COUNSEL
ONE
JOHNSON & JOHNSON PLAZA
NEW
BRUNSWICK, NJ 08933-0026
(732)
524-2452
FAX: (732)
524-2185
SROSENB@CORUS.JNJ.COM
February
14, 2008
Mr. Tim
Buchmiller
Senior
Attorney
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
Mail Stop
6010
100 F
Street, N.E.
Washington,
DC 20549
Re:
Letter
dated November 29, 2007 Regarding Definitive Proxy Statement Filed March
14, 2007 (File No. 001-03215)
Dear
Mr. Buchmiller:
The
following sets forth the responses of Johnson & Johnson (the “Company”) to
the comments on the above referenced proxy statement in your letter of November
29, 2007 to our Chairman and Chief Executive Officer, Mr. William C. Weldon. For
you convenience, we have included your comments with the letter. Our responses
use the same numbering as your letter.
Annual
Performance Bonus. page 18
Comment
1: We note from your response to prior comment 5 that you may
omit specific targets or performance objectives in your future filings if you
believe it is appropriate to do so. If the specific targets or performance
objectives that you may omit in future filings are similar to the targets or
objectives that you omitted in your definitive proxy statement filed on March
14, 2007, please provide us with a detailed explanation supporting your
conclusion that disclosure of those targets or objectives would result in
competitive harm such that the information could be excluded under Instruction 4
to Item 402(b) of Regulation S-K.
Response: The
Company notes the staff’s comment. If the specific targets or performance
objectives for 2007 disclosed in its 2008 Proxy Statement are similar to the
specific targets or objectives that the Company omitted in its March 14, 2007
Proxy Statement and are material, then the Company will disclose those 2007
targets and objectives in its 2008 Proxy Statement.
2006 Bonus and Long-Term
Incentive Awards…, page 22
Comment
2: It is not clear from your response to prior comment 6 that
you will identify the companies in your financial peer group in your future
filings. Please tell us whether you will identify the companies in your
financial peer group in future filings.
Response: The
Company notes the staff’s comment. The Company will identify the companies in
its 2007 financial peer groups in its 2008 Proxy Statement.
If you have any questions or comments,
please call Douglas Chia, Senior Counsel and Assistant Corporate Secretary at
732-524-3292 or me at 732-524-2452.
Very
truly yours,
/s/
Steven M. Rosenberg
Steven
M. Rosenberg
SMR/cms
CORPSECGEN\SECltrFeb08
cc: W. C. Weldon
R. C.
Deyo
D. K.
Chia