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SEC Comment Letter for WPP plc (WPP, WPPGF) (CIK 0000806968) (WPP) — Mar 27, 2013

WPP plc (WPP, WPPGF) (CIK 0000806968)
Date: March 27, 2013 · CIK: 0000806968 · Accession: 0000000000-13-016121

AI Filing Summary & Sentiment

Referenced dates: December 13, 2012

Date
December 31, 2011
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
WPP plc (WPP, WPPGF) (CIK 0000806968)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE March 26 , 2013 Via E-mail Paul Richardson Finance Director WPP plc 6 Ely Place Dublin 2 Ireland

Re: WPP plc Form 20-F for the Fiscal Year Ended December 31, 2011 Filed April 30 , 2012 File No. 0-16350 Response letter filed March 12, 2013

Dear Mr. Richardson :

We have reviewed your response letter and have the following comments.

Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may have additional comments.

General

1. We note that your response to comment 1 in our letter dated December 13, 2012 includes information regarding services subsidiaries provided in or relating to Iran. Please clarify for us your statement on page 18 of th e 20-F that the Group has no operations in Iran. If you make this statement in future filings, please also make clear that you have Iran -related operations, by adding information about subsidiaries providing services in or relating to Iran.

Paul Richardson WPP plc March 26, 2013 Page 2

Please contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 - 3470 if you have any questions about the comments or our review.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE  COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE

March 26 , 2013

Via E-mail
Paul Richardson
Finance Director
WPP plc
6 Ely Place
Dublin 2
Ireland

 Re: WPP plc
  Form 20-F for the Fiscal Year Ended December 31, 2011
  Filed April 30 , 2012
  File No. 0-16350
  Response letter filed March 12, 2013

Dear Mr. Richardson :

We have reviewed your response letter and have the following comments.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response. If you do
not believe our comments apply to your facts and circumstances, please tell us why in
your response.

After reviewing the information you provide in response to these comments, we
may have additional comments.

General

1. We note that your response to comment 1 in our letter dated December 13, 2012
includes information regarding services subsidiaries provided in or relating to Iran.
Please clarify for us your statement on page 18 of th e 20-F that the Group has no
operations in Iran.  If you make this statement in future filings, please also make clear
that you have Iran -related operations, by adding information about subsidiaries
providing services in or relating to Iran.

Paul Richardson
WPP plc
March 26, 2013
Page 2

 Please contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

                  Sincerely,

                   /s/ Cecilia Blye

                  Cecilia Blye, Chief
                  Office of Globa l Security Risk

cc:  Larry Spirgel
  Assistant Director
 Division of Corporation Finance