SEC Comment Letter for AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717) (T) — Jan 29, 2008
AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717)
Date: Jan. 29, 2008 · CIK: 0000732717 · Accession: 0000000000-08-004881
AI Filing Summary & Sentiment
File numbers found in text: 001-08610
Referenced dates: November 30, 2007, September 27, 2007
Letter
Re: AT&T Inc. Definitive Schedule 14A Filed March 22, 2007 File No. 001-08610 Dear Mr. Wirtz: We have reviewed your response letter dated November 30, 2007 and have the following comment. Please respond to our comment by February 1, 2008, or tell us by that time when you will provide us with a re sponse. If the comment requests revised disclosure in future filings, please confir m in writing that you will comply with the comment in your future filings and also e xplain to us how you intend to comply. We welcome any questions you may have about our comments or any other aspect of our review. Compensation Discussion and Analysis, page 32
January 18, 2008 Mail Stop 3720 By U.S. Mail and facsimile to (210) 351-3467
Wayne A. Wirtz Associate General Counsel Legal Department AT&T Inc. 175 E. Houston, Room 205 San Antonio, TX 78205
Short-Term Incentives, page 33 1. We have considered your response to co mment six in our letter dated September 27, 2007. Please provide a more comprehensiv e analysis as to why disclosure of each performance target would not be ma terial or would cause you competitive harm. Your response should be a thorough and detailed analysis focusing on the specific facts and circumstances of your business, each performance target and your compensation policies and decisions for each named executive officer.
Mr. Wayne A. Wirtz AT&T Inc. January 18, 2008 Page 2 Please contact me at (202) 551-3350 with any questions. S i n c e r e l y , K a t h l e e n K r e b s S p e c i a l C o u n s e l
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January 18, 2008
Mail Stop 3720
By U.S. Mail and facsimile to (210) 351-3467
Wayne A. Wirtz
Associate General Counsel Legal Department AT&T Inc. 175 E. Houston, Room 205 San Antonio, TX 78205
Re: AT&T Inc.
Definitive Schedule 14A Filed March 22, 2007
File No. 001-08610
Dear Mr. Wirtz:
We have reviewed your response letter dated November 30, 2007 and have the
following comment. Please respond to our comment by February 1, 2008, or tell us by
that time when you will provide us with a re sponse. If the comment requests revised
disclosure in future filings, please confir m in writing that you will comply with the
comment in your future filings and also e xplain to us how you intend to comply. We
welcome any questions you may have about our comments or any other aspect of our review.
Compensation Discussion and Analysis, page 32
Short-Term Incentives, page 33
1. We have considered your response to co mment six in our letter dated September
27, 2007. Please provide a more comprehensiv e analysis as to why disclosure of
each performance target would not be ma terial or would cause you competitive
harm. Your response should be a thorough and detailed analysis focusing on the
specific facts and circumstances of your business, each performance target and your compensation policies and decisions for each named executive officer.
Mr. Wayne A. Wirtz
AT&T Inc. January 18, 2008 Page 2
Please contact me at (202) 551-3350 with any questions.
S i n c e r e l y , K a t h l e e n K r e b s S p e c i a l C o u n s e l