SEC Comment Letter for HONEYWELL INTERNATIONAL INC (HON) (CIK 0000773840) (HON) — Jan 21, 2015
HONEYWELL INTERNATIONAL INC (HON) (CIK 0000773840)
Date: Jan. 21, 2015 · CIK: 0000773840 · Accession: 0000000000-15-002871
AI Filing Summary & Sentiment
Referenced dates: December 15, 2014
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE January 21, 2015 Via E-mail Adam M. Matteo 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 , 2013 Filed February 14 , 2014 File No. 1-08974
Dear M r. Matte o:
We refer you to our comment letter dated December 15, 2014 regarding business contacts with Sudan and Syria. We have completed our review of this subject matter. We remind you that our comments or changes 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 Act of 1934 and all applicable rules require .
Sincerely,
/s/ Cecilia Blye
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
January 21, 2015
Via E-mail
Adam M. Matteo
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 , 2013
Filed February 14 , 2014
File No. 1-08974
Dear M r. Matte o:
We refer you to our comment letter dated December 15, 2014 regarding business contacts
with Sudan and Syria. We have completed our review of this subject matter. We remind you
that our comments or changes 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 Act of 1934 and all applicable rules
require .
Sincerely,
/s/ Cecilia Blye
Cecilia Blye, Chief
Office of Global Security Risk
cc: Anne Nguyen Parker
Assistant Director
Division of Corporation Finance