SEC Company Response from CHURCH & DWIGHT CO (CHD) — Apr 28, 2005
CHURCH & DWIGHT CO INC /DE/ (CHD) (CIK 0000313927)
Date: April 28, 2005 · CIK: 0000313927 · Accession: 0001193125-05-088833
AI Filing Summary & Sentiment
Referenced dates: April 26, 2005
Letter
VIA EDGAR AND OVERNIGHT DELIVERY Securities and Exchange Commission Attention: Division of Corporation Finance Annual Report on Form 10-K for the fiscal year ended December 31, 2004 Filed March 11, 2005 File No. 1-10585
Dear Ms. Hardy:
On behalf of Church & Dwight Co., Inc. (the “Company”), we are responding to the comment of the staff of the Securities and Exchange Commission (the “Commission”) set forth in your letter dated April 26, 2005 to James R. Craigie, President and Chief Executive Officer of the Company, with respect to the above-referenced Annual Report on Form 10-K for the year ended December 31, 2004 (the “Church & Dwight 10-K”).
For your convenience we have reproduced the staff’s comment in italics below followed by the Company’s response to your comments.
Comment:
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.
Securities and Exchange Commission
April 28, 2005
Page 2
Company response:
In future filings, the Company will not include the sentence beginning with the words: “A controls system cannot provide absolute assurance, however, that the objectives of the controls system are met . . .”.
Accompanying this letter is the written statement from the Company requested in your letter.
Thank you for your consideration. If you have any questions or comments, please contact me at (215) 963-5224.
Very truly yours,
/s/ Alan Singer
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Correspondence Letter
Morgan, Lewis & Bockius LLP
1701 Market Street
Philadelphia, PA 19103-2921
Tel: 215.963.5000
Fax: 215.963.5001
www.morganlewis.com
Alan Singer
215-963-5224
asinger@morganlewis.com
April 28, 2005
VIA EDGAR AND OVERNIGHT DELIVERY
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Attention:
Jennifer R. Hardy, Legal Branch Chief
Division of Corporation Finance
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 Ms. Hardy:
On behalf of Church & Dwight Co., Inc. (the “Company”), we are responding to the comment of the staff of the Securities and
Exchange Commission (the “Commission”) set forth in your letter dated April 26, 2005 to James R. Craigie, President and Chief Executive Officer of the Company, with respect to the above-referenced Annual Report on Form 10-K for the year
ended December 31, 2004 (the “Church & Dwight 10-K”).
For your
convenience we have reproduced the staff’s comment in italics below followed by the Company’s response to your comments.
Comment:
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.
Securities and Exchange Commission
April 28, 2005
Page 2
Company response:
In future filings, the Company will not include the sentence beginning with the words: “A controls system cannot provide absolute assurance, however,
that the objectives of the controls system are met . . .”.
Accompanying
this letter is the written statement from the Company requested in your letter.
Thank you for your consideration. If you have any questions or comments, please contact me at (215) 963-5224.
Very truly yours,
/s/ Alan Singer
AS
Enclosure
cc:
Mr. Zvi Eiref
Susan A. Goldy, Esquire
Edward M. Kelly, Esquire