SEC Company Response from WPP plc (WPP, WPPGF) (CIK 0000806968) (WPP) — Apr 12, 2013
WPP plc (WPP, WPPGF) (CIK 0000806968)
Date: April 12, 2013 · CIK: 0000806968 · Accession: 0001193125-13-152847
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 13, 2012, March 26, 2013
Letter
Office of Global Security Risk Securities and Exchange Commission Division of Corporation Finance 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 Ms. Blye:
On behalf of WPP plc (the “Company”), this letter responds to the comment received from the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) in a letter dated March 26, 2013 (the “Comment Letter”) pertaining to the captioned report on Form 20-F. For ease of reference in this letter, the Commission’s comment contained in the Comment Letter is reproduced in bold in this letter and the corresponding response of the Company is shown below the comment.
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 the 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.
The statement that the Group has no operations in Iran meant that the Group does not have any offices in, or personnel conducting business from within, that country. As noted in our response letter filed March 12, 2013, Group companies occasionally use third parties to provide services in Iran or book media space within Iran for their clients, and other Group companies occasionally analyze data relating to Iran provided by clients or third parties. In one instance a Group company also provided advertising services outside Iran to a German company owned by an Iranian national.
Cecelia Blye, Esq.
Securities and Exchange Commission
April 12, 2013
Page 2
If WPP states in future filings that the Group has no operations in Iran we will clarify in any such statement the extent to which subsidiaries provide services in or relating to Iran.
Please do not hesitate to contact the undersigned at (212) 468-4944 if you have any further comments or questions.
Very truly yours,
/s/ Ralph W. Norton
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CORRESP 1 filename1.htm CORRESPONDENCE Davis & Gilbert LLP 1740 Broadway New York, NY 10019 Direct Dial: 212.468.4944 Personal Fax: 212.974.6969 Email: rnorton@dglaw.com April 12, 2013 Cecelia Blye, Esq., Chief Office of Global Security Risk Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 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 Ms. Blye: On behalf of WPP plc (the “Company”), this letter responds to the comment received from the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) in a letter dated March 26, 2013 (the “Comment Letter”) pertaining to the captioned report on Form 20-F. For ease of reference in this letter, the Commission’s comment contained in the Comment Letter is reproduced in bold in this letter and the corresponding response of the Company is shown below the comment. 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 the 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. The statement that the Group has no operations in Iran meant that the Group does not have any offices in, or personnel conducting business from within, that country. As noted in our response letter filed March 12, 2013, Group companies occasionally use third parties to provide services in Iran or book media space within Iran for their clients, and other Group companies occasionally analyze data relating to Iran provided by clients or third parties. In one instance a Group company also provided advertising services outside Iran to a German company owned by an Iranian national. Cecelia Blye, Esq. Securities and Exchange Commission April 12, 2013 Page 2 If WPP states in future filings that the Group has no operations in Iran we will clarify in any such statement the extent to which subsidiaries provide services in or relating to Iran. Please do not hesitate to contact the undersigned at (212) 468-4944 if you have any further comments or questions. Very truly yours, /s/ Ralph W. Norton Ralph W. Norton Cc: Paul W. G. Richardson Mark Povey, Esq. Vicky Brown, Esq. Curt Myers, Esq.