SEC Company Response from MAGNA INTERNATIONAL (MGA) — Sep 6, 2007
MAGNA INTERNATIONAL INC
Date: Sept. 6, 2007 · CIK: 0000749098 · Accession: 0000905148-07-005945
AI Filing Summary & Sentiment
Reasoning
Referenced dates: August 23, 2007
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Merger and Acquisitions Attention: Office of Mergers and Acquisitions Amendment No. 1 to Schedule TO-I filed August 15, 2007 Amendment No. 2 to Schedule TO-I filed August 22, 2007 and Amendment No. 3 to Schedule TO-I filed herewith SEC File No. 5-43799
Dear Mr. Pressman:
On behalf of Magna International Inc. (“Magna”), we submit this letter in response to comments from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated August 23, 2007 relating to Magna’s Tender Offer Statement referred to above (as amended, the “Schedule TO”).
In response to your comments, and further to correspondence and related discussions through our outside counsel, Sidley Austin LLP, we are concurrently filing via EDGAR Amendment No. 3 to the Schedule TO (“Amendment No. 3”). Pursuant to your request, Magna hereby acknowledges that:
·
Magna is responsible for the adequacy and accuracy of the disclosure in its filings;
·
Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing; and
·
Magna may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very
truly yours,
/sgd/
Bassem Shakeel
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Magna
International Inc.
337
Magna Drive
Aurora,
Ontario, Canada L4G 7K1
Tel (905)
726-2462
Fax (905)
726-7164
September
6, 2007
VIA
EDGAR
United
States Securities and Exchange Commission
Division
of Corporation Finance
Office
of
Merger and Acquisitions
100
F
Street, N.E.
Washington,
D.C. 20549-0303
Attention:
Mr.
Michael Pressman
Special Counsel
Office of Mergers and
Acquisitions
Re:
Magna
International Inc.
Schedule
TO-I filed August 14, 2007
Amendment
No. 1 to Schedule TO-I filed August 15, 2007
Amendment
No. 2 to Schedule TO-I filed August 22, 2007 and
Amendment
No. 3 to Schedule TO-I filed herewith
SEC
File No. 5-43799
Dear
Mr.
Pressman:
On
behalf
of Magna International Inc. (“Magna”), we submit this letter in response to
comments from the Staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) received by letter dated August 23, 2007 relating to Magna’s
Tender Offer Statement referred to above (as amended, the “Schedule
TO”).
In
response to your comments, and further to correspondence and related discussions
through our outside counsel, Sidley Austin LLP, we are concurrently filing
via
EDGAR Amendment No. 3 to the Schedule TO (“Amendment No.
3”). Pursuant to your request, Magna hereby acknowledges
that:
·
Magna
is responsible for the adequacy and accuracy of the disclosure in
its
filings;
·
Staff
comments or changes to disclosure in response to Staff comments in
the
filings reviewed by the Staff do not foreclose the Commission from
taking
any action with respect to the filing;
and
·
Magna
may not assert Staff comments as a defense in any proceeding initiated
by
the Commission or any person under the federal securities laws of
the
United States.
Very
truly yours,
/sgd/
Bassem Shakeel
Bassem
A.
Shakeel
Senior
Legal Counsel
and
Assistant Secretary