SEC Company Response from REEBOK INTERNATIONAL LTD (CIK 0000770949) — Nov 9, 2005
REEBOK INTERNATIONAL LTD (CIK 0000770949)
Date: Nov. 9, 2005 · CIK: 0000770949 · Accession: 0001104659-05-054209
AI Filing Summary & Sentiment
File numbers found in text: 001-09340, 001-9340
Referenced dates: October 19, 2005
Letter
Securities and Exchange Commission Division of Corporate Finance Attention: File No. 001-09340 Form 10-Q for the period ended June 30, 2005 Filed August 9, 2005 File No. 001-09340
Dear Ms. Long:
Please be advised that, in connection with the comments issued by the Staff of the Securities and Exchange Commission (the “Commission”) contained in its letter dated October 19, 2005 to Reebok International Ltd. (the “Company”) that pertain to the Company’s Preliminary Proxy Statement on Schedule 14A filed on September 21, 2005 (File No. 001-09340), Form 10-K for the year ended December 31, 2004 filed April 15, 2005 (File No. 001-9340) and Form 10-Q for the period ended June 30, 2005 filed August 9, 2005 (File No. 001-9340) and the Company’s responses thereto, the Company hereby acknowledges that (i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings, (ii) Staff comments or changes to disclosure in response to Staff comments does not foreclose the Commission from taking any actions with respect to the Company’s filings, and (iii) the Company may not assert Staff comments as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very Truly Yours,
/s/ David A. Pace
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CORRESP 1 filename1.htm [REEBOK INTERNATIONAL LTD. LETTERHEAD] November 8, 2005 Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E., Mail Stop 7010 Washington, DC 20549 Attention: Pamela A. Long, Assistant Director Re: Reebok International Ltd. Preliminary Proxy Statement on Schedule 14A Filed September 21, 2005 File No. 001-09340 Form 10-K for the year ended December 31, 2004 Filed April 15, 2005 File No. 001-09340 Form 10-Q for the period ended June 30, 2005 Filed August 9, 2005 File No. 001-09340 Dear Ms. Long: Please be advised that, in connection with the comments issued by the Staff of the Securities and Exchange Commission (the “Commission”) contained in its letter dated October 19, 2005 to Reebok International Ltd. (the “Company”) that pertain to the Company’s Preliminary Proxy Statement on Schedule 14A filed on September 21, 2005 (File No. 001-09340), Form 10-K for the year ended December 31, 2004 filed April 15, 2005 (File No. 001-9340) and Form 10-Q for the period ended June 30, 2005 filed August 9, 2005 (File No. 001-9340) and the Company’s responses thereto, the Company hereby acknowledges that (i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings, (ii) Staff comments or changes to disclosure in response to Staff comments does not foreclose the Commission from taking any actions with respect to the Company’s filings, and (iii) the Company may not assert Staff comments as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Very Truly Yours, /s/ David A. Pace David A. Pace Senior Vice President, General Counsel and Clerk Reebok International Ltd.