SEC Company Response from ADELPHIA COMMUNICATIONS CORP (CIK 0000796486) — Oct 24, 2005
ADELPHIA COMMUNICATIONS CORP (CIK 0000796486)
Date: Oct. 24, 2005 · CIK: 0000796486 · Accession: 0001104659-05-049835
AI Filing Summary & Sentiment
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Re: Adelphia Communications Corporation (“Adelphia” or the “Company”) Form 10-K for December 31, 2003 Filed December 23, 2004 File No. 0-16014
Dear Mr. Spirgel:
Pursuant to the Staff’s request in its phone conversation with the Company’s SEC counsel, David Martin of Covington & Burling, on October 11, 2005, this letter responds to a question raised by the Staff in a conference call with the Company and PricewaterhouseCoopers LLP on September 15, 2005. The Staff’s question appears below in italics and is followed by the Company’s response.
1. [* * *]
[* * *]
* * * * * * * *
REQUEST FOR CONFIDENTIAL TREATMENT
Adelphia hereby requests confidential treatment of this letter pursuant to the provisions of Rule 83 of the Commission’s Rules Concerning Information and Requests. More specifically, we request that the SEC staff not disclose this letter, or any memoranda, notes, correspondence or other writings made by the SEC or the SEC staff relating to this letter or to any telephone call or meeting with respect thereto, or any copies or extracts of any of the foregoing, in response to any request under the Freedom of Information Act (“FOIA”), 5 U.S.C. Section 522.
CONFIDENTIAL TREATMENT REQUESTED
BY ADELPHIA COMMUNICATIONS CORPORATION
Pursuant to Rule 83, if a FOIA request for this letter or any of the related material identified in the immediately preceding paragraph is received by the SEC staff during the pendency of this request, we understand that Adelphia will be so informed and be asked at that time to submit its formal application for confidential treatment. We understand that this submission shall be valid for ten years from the date hereof.
All notices, orders and requests for substantiation of this confidential treatment request under Rule 83 should be directed to:
Adelphia Communications Corporation
DTC Parkway
Greenwood Village, CO 80111
Attention: Brad M. Sonnenberg
Executive Vice President, General Counsel and Secretary
Telephone: (303) 268-6300
Facsimile: (303) 268-6662
* * * * * * * *
Please do not hesitate to call me at (303) 268-6370 or our counsel David Martin of Covington & Burling at (202) 662-5128 with any questions. Thank you.
Sincerely,
/s/ Scott D. Macdonald
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CORRESP
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filename1.htm
ADELPHIA COMMUNICATIONS
CORPORATION
5619 DTC Parkway
Greenwood Village, CO 80111
October 24, 2005
VIA EDGAR
Larry
M. Spirgel
Assistant
Director
Securities
and Exchange Commission
Division
of Corporation Finance
100
F Street, N.E.
Washington,
D.C. 20549
Re: Adelphia Communications Corporation (“Adelphia”
or the “Company”)
Form 10-K for December 31, 2003
Filed December 23, 2004
File No. 0-16014
Dear
Mr. Spirgel:
Pursuant to the Staff’s request
in its phone conversation with the Company’s SEC counsel, David Martin of
Covington & Burling, on October 11, 2005, this letter responds to
a question raised by the Staff in a conference call with the Company and
PricewaterhouseCoopers LLP on September 15, 2005. The Staff’s question appears below in italics
and is followed by the Company’s response.
1. [* * *]
[* *
*]
* * * * * * * *
REQUEST
FOR CONFIDENTIAL TREATMENT
Adelphia
hereby requests confidential treatment of this letter pursuant to the
provisions of Rule 83 of the Commission’s Rules Concerning
Information and Requests. More
specifically, we request that the SEC staff not disclose this letter, or any
memoranda, notes, correspondence or other writings made by the SEC or the SEC
staff relating to this letter or to any telephone call or meeting with respect
thereto, or any copies or extracts of any of the foregoing, in response to any
request under the Freedom of Information Act (“FOIA”), 5 U.S.C. Section 522.
CONFIDENTIAL TREATMENT REQUESTED
BY ADELPHIA COMMUNICATIONS CORPORATION
Pursuant
to Rule 83, if a FOIA request for this letter or any of the related
material identified in the immediately preceding paragraph is received by the
SEC staff during the pendency of this request, we understand that Adelphia will
be so informed and be asked at that time to submit its formal application for
confidential treatment. We understand
that this submission shall be valid for ten years from the date hereof.
All
notices, orders and requests for substantiation of this confidential treatment
request under Rule 83 should be directed to:
Adelphia
Communications Corporation
5619
DTC Parkway
Greenwood
Village, CO 80111
Attention: Brad M. Sonnenberg
Executive
Vice President, General Counsel and Secretary
Telephone:
(303) 268-6300
Facsimile: (303) 268-6662
* * * * * * * *
Please do not hesitate to
call me at (303) 268-6370 or our counsel David Martin of Covington &
Burling at (202) 662-5128 with any questions.
Thank you.
Sincerely,
/s/ Scott D. Macdonald
Scott D. Macdonald
Senior Vice President &
Chief Accounting Officer
[* * *] indicates redacted material.
cc: Ted Yu
Kathleen Krebs
Melissa Hauber
Carlos
Pacho
Sondra
Stokes
Securities and Exchange Commission
William
T. Schleyer
Vanessa
A. Wittman
Brad
M. Sonnenberg
Luci
Altman
Adelphia Communications Corporation
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David
B.H. Martin
Bruce
C. Bennett
Covington & Burling
Office
of Freedom of Information and Privacy Act Operations
Securities and Exchange Commission Operations
Center
6432 General Green Way
Alexandria, VA 22312-2413
3