SEC Comment Letter for CHURCH & DWIGHT CO (CHD) — Apr 26, 2005
CHURCH & DWIGHT CO INC /DE/ (CHD) (CIK 0000313927)
Date: April 26, 2005 · CIK: 0000313927 · Accession: 0000000000-05-020242
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<TYPE>LETTER
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<FILENAME>filename1.txt
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April 26, 2005
By facsimile to (609) 497-7175 and U.S. Mail
Mr. James R. Craigie
President and Chief Executive Officer
Church & Dwight Co., Inc.
469 North Harrison Street
Princeton, NJ 08543-5297
RE: Church & Dwight Co., Inc.
Annual Report on Form 10-K for the fiscal year ended December
31, 2004
Filed March 11, 2005
File No. 1-10585
Dear Mr. Craigie:
We limited our review of the filing to disclosures under Item
9A
of Form 10-K and have the comment below.
Item 9A. Controls and Procedures
1. We note your statement under (a) that "A controls system cannot
provide absolute assurance, however, that the objectives of the
control system are met." Revise in future filings to state
clearly,
if true, that your disclosure controls and procedures are designed
to
provide reasonable assurance of achieving their objectives and
that
your principal executive officer and principal financial officer
concluded that your disclosure controls and procedures are
effective
at that reasonable assurance level. Alternatively, remove in
future
filings the reference to the level of assurance of your disclosure
controls and procedures. Refer to section II.F.4. of Release No.
34-
47986 that is available on the Commission`s website at
www.sec.gov.
Closing
As appropriate, respond to the comment within 10 business
days
or tell us when you will provide us a response. If you think that
compliance with the comment is inappropriate, provide the basis in
the letter. We may have additional comments after review of the
response to the comment.
We urge all persons responsible for the accuracy and adequacy
of
the disclosures in the filing reviewed by us to make certain that
they have provided all information that investors require for an
informed decision. Since Church & Dwight and its management are
in
possession of all facts relating to the disclosures in the filing,
they are responsible for the adequacy and accuracy of the
disclosures
that they have made.
When responding to our comment, provide a written statement
from Church & Dwight acknowledging that:
* Church & Dwight is responsible for the adequacy and accuracy of
the
disclosures in the filing.
* Our comment or changes to disclosures in response to our comment
do
not foreclose the Commission from taking any action on the filing.
* Church & Dwight may not assert our comment as a defense in any
proceedings initiated by the Commission or any person under the
United States` federal securities laws.
The Commission`s Division of Enforcement has access to all
information that you provide us in our review of the filings or in
response to our comments on the filings.
You may direct questions on the comment and other disclosure
issues to Edward M. Kelly, Senior Counsel, at (202) 942-1978 or me
at
(202) 942-2864
Very truly yours,
Jennifer R. Hardy
Legal
Branch Chief
Mr. James R. Craigie
April 26, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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