SEC Comment Letter for UNISYS CORP (UIS) (CIK 0000746838) (UIS) — Feb 25, 2008
UNISYS CORP (UIS) (CIK 0000746838)
Date: Feb. 25, 2008 · CIK: 0000746838 · Accession: 0000000000-08-009632
AI Filing Summary & Sentiment
File numbers found in text: 001-08729
Referenced dates: November 2, 2007
Letter
Mail Stop 4561
November 29, 2007
By U.S. Mail and facsimile to (215) 986-5596
Joseph W. McGrath, Chief Executive Officer Unisys Corporation Unisys Way Blue Bell, PA 19424-0001 Re: Unisys Corporation Definitive 14A Filed March 19, 2007 File No. 001-08729 Dear Mr. McGrath: We have reviewed your response letter dated November 2, 2007 and have the following comment. Please respond to our comment by December 13, 2007 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. 1. Refer to comment 8 of our letter date d August 21, 2007. Please provide a more detailed analysis justifying the omission of disclosure relating to group revenue and pre-tax profit performance. The cr iterion for applying the exemption is a reasonable showing that disclosure would cause substantial competitive harm. Such a showing is not satisfied by general statements that some harm will occur, such as that made at the top of page 4 of your response.
Joseph W. McGrath Unisys Corporation November 29, 2007 Page - 2 -
2Please contact me at (202) 551-3397 with any questions.
Sincerely, Jay E. Ingram Attorney Advisor
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Mail Stop 4561 November 29, 2007 By U.S. Mail and facsimile to (215) 986-5596 Joseph W. McGrath, Chief Executive Officer Unisys Corporation Unisys Way Blue Bell, PA 19424-0001 Re: Unisys Corporation Definitive 14A Filed March 19, 2007 File No. 001-08729 Dear Mr. McGrath: We have reviewed your response letter dated November 2, 2007 and have the following comment. Please respond to our comment by December 13, 2007 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. 1. Refer to comment 8 of our letter date d August 21, 2007. Please provide a more detailed analysis justifying the omission of disclosure relating to group revenue and pre-tax profit performance. The cr iterion for applying the exemption is a reasonable showing that disclosure would cause substantial competitive harm. Such a showing is not satisfied by general statements that some harm will occur, such as that made at the top of page 4 of your response. Joseph W. McGrath Unisys Corporation November 29, 2007 Page - 2 - 2Please contact me at (202) 551-3397 with any questions. Sincerely, Jay E. Ingram Attorney Advisor