SEC Comment Letter for Merck & Co., Inc. (MRK) (CIK 0000310158) (MRK) — Mar 30, 2005
Merck & Co., Inc. (MRK) (CIK 0000310158)
Date: March 30, 2005 · CIK: 0000310158 · Accession: 0000000000-05-015106
AI Filing Summary & Sentiment
Letter
March 25, 2005 Via U.S. Mail Fred Hassan Chief Executive Officer Schering-Plough Corporation 2000 Galloping Hill Road Kenilworth, N.J.
RE: Schering-Plough Corporation Form 10-K for the fiscal year ended December 31, 2004 File No. 1-6571
Dear Mr. Hassan:
We have limited our review of your Form 10-K to disclosures relating to your contacts with countries that have been identified as state sponsors of terrorism, and will make no further review of the Form 10-K. 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 supplemental information, so that we may better understand your disclosure. Please be as detailed as necessary in your response. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General -
We note that in Exhibit 21 to the Company`s 10-K for the fiscal year ended December 31, 2004, the Company lists an Iranian subsidiary named Schering-Plough Limited. In light of the fact that Iran has been identified by the U.S. State Department as a state sponsor of terrorism, and is subject to economic sanctions administered by the U.S. Treasury Department`s Office of Foreign Assets Control, please describe for us the extent of the Company`s operations in Iran; the materiality to the Company of any operations in Iran; and your view as to whether those operations constitute a material investment risk for your security holders. In preparing your response please consider that evaluations of materiality should not be based solely on quantitative factors, but should include consideration of all factors, including the potential impact of corporate activities upon a company`s reputation and share value, that a reasonable investor would deem important in making an investment decision.
Closing
Please understand that we may have additional comments after we review your response to our comment. Please contact Jack Guggenheim at (202) 942-7896 if you have any questions about the comment or our review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
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<TEXT>
March 25, 2005
Via U.S. Mail
Fred Hassan
Chief Executive Officer
Schering-Plough Corporation
2000 Galloping Hill Road
Kenilworth, N.J.
RE: Schering-Plough Corporation
Form 10-K for the fiscal year ended December 31, 2004
File No. 1-6571
Dear Mr. Hassan:
We have limited our review of your Form 10-K to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 10-K. 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
supplemental information, so that we may better understand your
disclosure. Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
General -
We note that in Exhibit 21 to the Company`s 10-K for the fiscal
year
ended December 31, 2004, the Company lists an Iranian subsidiary
named Schering-Plough Limited. In light of the fact that Iran has
been identified by the U.S. State Department as a state sponsor of
terrorism, and is subject to economic sanctions administered by
the
U.S. Treasury Department`s Office of Foreign Assets Control,
please
describe for us the extent of the Company`s operations in Iran;
the
materiality to the Company of any operations in Iran; and your
view
as to whether those operations constitute a material investment
risk
for your security holders. In preparing your response please
consider that evaluations of materiality should not be based
solely
on quantitative factors, but should include consideration of all
factors, including the potential impact of corporate activities
upon
a company`s reputation and share value, that a reasonable investor
would deem important in making an investment decision.
Closing
Please understand that we may have additional comments after
we
review your response to our comment. Please contact Jack
Guggenheim
at (202) 942-7896 if you have any questions about the comment or
our
review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Jeffrey Riedler
Assistant Director
Division of Corporation Finance
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