SEC Comment Letter for HONEYWELL INTERNATIONAL INC (HON) (CIK 0000773840) (HON) — Aug 15, 2011
HONEYWELL INTERNATIONAL INC (HON) (CIK 0000773840)
Date: Aug. 15, 2011 · CIK: 0000773840 · Accession: 0000000000-11-049321
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-8974
Referenced dates: June 9, 2011
Letter
Re: Honeywell International Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 11, 2011 File No. 001-8974 Dear Ms. Winters: We refer you to our comment letters dated June 9, 2011 and July 22, 2011 regarding business contacts with Iran, Syria and Sudan. We have completed our review of this subject matter. We remind you that our comments or change s to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Ac t of 1934 and all applic able rules require.
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4628
DIVISION OF CORPORATION FINANCE
August 15, 2011 Via Facsimile
Kathleen A. Winters Vice President and Controller Honeywell International Inc. 101 Columbia Road Morris Township, NJ 07962
S i n c e r e l y ,
/s/ Cecilia Blye C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Max Webb Assistant Director Division of Cor poration Finance
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628
DIVISION OF
CORPORATION FINANCE
August 15, 2011
Via Facsimile
Kathleen A. Winters
Vice President and Controller Honeywell International Inc. 101 Columbia Road
Morris Township, NJ 07962
Re: Honeywell International Inc.
Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 11, 2011 File No. 001-8974
Dear Ms. Winters:
We refer you to our comment letters dated June 9, 2011 and July 22, 2011
regarding business contacts with Iran, Syria and Sudan. We have completed our review
of this subject matter. We remind you that our comments or change s to disclosure in
response to our comments do not foreclose the Commission from taking any action with
respect to the company or the filing and the company 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. We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes
the information the Securities Exchange Ac t of 1934 and all applic able rules require.
S i n c e r e l y ,
/s/ Cecilia Blye C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Max Webb Assistant Director Division of Cor poration Finance