SEC Comment Letter for Merck & Co., Inc. (MRK) (CIK 0000310158) (MRK) — Dec 5, 2007
Merck & Co., Inc. (MRK) (CIK 0000310158)
Date: Dec. 5, 2007 · CIK: 0000310158 · Accession: 0000000000-07-059061
AI Filing Summary & Sentiment
File numbers found in text: 001-06571
Referenced dates: September 21, 2007
Letter
Mail Stop 6010
December 5, 2007
Grace K. Lee Senior Counsel and Deputy Secretary Schering-Plough Corporation 2000 Galloping Hill Road Kenilworth, NJ 07033 Re: Schering-Plough Corporation Definitive Proxy Statement Filed April 20, 2007 File No. 001-06571 Dear Ms. Lee: We have reviewed your response letter dated September 21, 2007 and have the following comments. Please respond to our comments by December 19, 2007 or tell us by that time when you will provide us with a response. If the comments request revised disclosure in future filings, please confir m in writing that you will comply with the comments in your future filings and also ex plain to us how you intend to comply. We welcome any questions you may have about our comments or any other aspect of our review. 1. We note your response to prior comments 5, 8 and 9. In your future filings, as applicable, please confirm that you will include disclosure that reflects the substance of those responses in your Compensation Discussion and Analysis. 2. We note your response to prior comment 7. As requested by that comment, please confirm that the Compensation Di scussion and Analysis in your future filings will provide substantive analysis and insight into how the compensation committee determined the actual amo unts awarded to each named executive officer under each element of your equity and other forms of long-term compensation.
Schering-Plough Corporation December 5, 2007 Page 2 If you have any questions, pleas e contact me at (202) 551-3635. S i n c e r e l y , T i m B u c h m i l l e r S e n i o r A t t o r n e y
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Mail Stop 6010
December 5, 2007
Grace K. Lee
Senior Counsel and Deputy Secretary Schering-Plough Corporation 2000 Galloping Hill Road Kenilworth, NJ 07033
Re: Schering-Plough Corporation Definitive Proxy Statement
Filed April 20, 2007
File No. 001-06571
Dear Ms. Lee:
We have reviewed your response letter dated September 21, 2007 and have the
following comments. Please respond to our comments by December 19, 2007 or tell us
by that time when you will provide us with a response. If the comments request revised disclosure in future filings, please confir m in writing that you will comply with the
comments in your future filings and also ex plain to us how you intend to comply. We
welcome any questions you may have about our comments or any other aspect of our review. 1. We note your response to prior comments 5, 8 and 9. In your future filings, as
applicable, please confirm that you will include disclosure that reflects the
substance of those responses in your Compensation Discussion and Analysis.
2. We note your response to prior comment 7. As requested by that comment,
please confirm that the Compensation Di scussion and Analysis in your future
filings will provide substantive analysis and insight into how the compensation
committee determined the actual amo unts awarded to each named executive
officer under each element of your equity and other forms of long-term compensation.
Schering-Plough Corporation December 5, 2007 Page 2
If you have any questions, pleas e contact me at (202) 551-3635.
S i n c e r e l y , T i m B u c h m i l l e r S e n i o r A t t o r n e y