SEC Comment Letter for AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717) (T) — Feb 21, 2008
AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717)
Date: Feb. 21, 2008 · CIK: 0000732717 · Accession: 0000000000-08-009137
AI Filing Summary & Sentiment
File numbers found in text: 001-08610
Letter
Re: AT&T Inc. Definitive Schedule 14A Filed March 22, 2007 File No. 001-08610 Dear Mr. Wirtz: We have reviewed your January 31, 2008 response to our comments of January 18, 2008. Without more detail, we cannot agre e or disagree with your conclusion that you have an appropriate basis to omit the identified performance targets related to:
February 20, 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
• year-over-year revenue targets fo r extraordinary bonus payments; • the performance targets for Mr. Sigman’s bonus; • return on invested capital targ ets in prior fiscal year pe riods for long-term incentive awards; and • AT&T Mobility’s earnings before interest and taxes return on capital targets for long- term incentive awards for Messrs. Sigman and Lindner. Since you are in possession of all of the facts related to your disclosure, we have decided that we have no basis to disa gree with your decision to omit this information from your filing. As in all cases, we remind you that you are responsible for the adequacy and accuracy of the disclosure in your filings. We do not have any further comments on your filing.
If you have any further questions regardi ng our review of your filing, please call me at (202) 551-3350. 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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February 20, 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 January 31, 2008 response to our comments of January 18, 2008. Without more detail, we cannot agre e or disagree with your conclusion that you have an appropriate basis to omit the identified performance targets related to: • year-over-year revenue targets fo r extraordinary bonus payments; • the performance targets for Mr. Sigman’s bonus; • return on invested capital targ ets in prior fiscal year pe riods for long-term incentive awards; and • AT&T Mobility’s earnings before interest and taxes return on capital targets for long- term incentive awards for Messrs. Sigman and Lindner. Since you are in possession of all of the facts related to your disclosure, we have decided that we have no basis to disa gree with your decision to omit this information from your filing. As in all cases, we remind you that you are responsible for the adequacy and accuracy of the disclosure in your filings. We do not have any further comments on your filing. If you have any further questions regardi ng our review of your filing, please call me at (202) 551-3350. 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