SEC Company Response from Merck & Co., Inc. (MRK) (CIK 0000310158) (MRK) — Dec 14, 2007
Merck & Co., Inc. (MRK) (CIK 0000310158)
Date: Dec. 14, 2007 · CIK: 0000310158 · Accession: 0000950123-07-016666
AI Filing Summary & Sentiment
Referenced dates: August 21, 2007, December 5, 2007
Letter
Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: Schering-Plough Corporation Definitive Proxy Statement filed April 20, 2007
Dear Mr. Buchmiller:
This letter responds to your letter dated December 5, 2007. On September 21, 2007, we responded to your initial letter dated August 21, 2007. Set below are each of the comments included in your December letter and Schering-Plough’s response.
1.
We note your responses 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.
In future proxy filings, we confirm that we will include disclosures that reflect the substances of our responses made in prior comments 5, 8 and 9 in our Compensation Discussion and Analysis.
2.
We note your response to prior comment 7. As requested by that comment, please confirm that the Compensation Discussion and Analysis in your future filings will provide substantive analysis and insight into how the compensation committee determined the actual amounts awarded to each named executive officer under each element of your equity and other forms of long-term compensation.
In future proxy filings, we confirm that we will provide substantive analysis and insight into how the Compensation Committee determined the actual amounts awarded to each named executive officer under each element of our equity of other forms of long-term compensation in our Compensation Discussion and Analysis.
If you have any questions or require additional information, please call me at (908) 298-7175 or Susan Ellen Wolf, Corporate Secretary, at (908) 298-7354.
Sincerely,
/s/ Grace K.
Lee
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CORRESP
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filename1.htm
RESPONSE LETTER
[SP Letterhead]
December 14,
2007
Tim
Buchmiller
Senior Attorney
Division of Corporation Finance
U.S. Securities Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Schering-Plough
Corporation
Definitive Proxy Statement filed April 20, 2007
Dear Mr. Buchmiller:
This
letter responds to your letter dated December 5, 2007. On September 21, 2007, we responded to
your initial letter dated August 21, 2007. Set below are each of the comments included in your
December letter and Schering-Plough’s response.
1.
We note your responses 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.
In
future proxy filings, we confirm that we will include disclosures that reflect the
substances of our responses made in prior comments 5, 8 and 9 in our Compensation
Discussion and Analysis.
2.
We note your response to prior comment 7. As requested by that
comment, please confirm that the Compensation Discussion and Analysis
in your future filings will provide substantive analysis and insight into how
the compensation committee determined the actual amounts awarded to each named
executive officer under each element of your equity and other forms of long-term compensation.
In
future proxy filings, we confirm that we
will provide substantive analysis and insight into how the Compensation Committee
determined the actual amounts awarded to each named executive officer under each element of our equity of
other forms of long-term compensation in our Compensation Discussion
and Analysis.
If you have any questions or require additional information,
please call me at (908) 298-7175 or Susan Ellen Wolf,
Corporate Secretary, at (908) 298-7354.
Sincerely,
/s/ Grace K.
Lee
Grace K.
Lee
Senior Counsel and Deputy Secretary
cc: Hans Becherer, Compensation
Committee Chair
Fred Hassan, Chairman and CEO
Ira Kay, consultant to the Compensation Committee
Susan Ellen Wolf, Corporate Secretary
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