SEC Company Response from WPP plc (WPP, WPPGF) (CIK 0000806968) (WPP) — Sep 6, 2018
WPP plc (WPP, WPPGF) (CIK 0000806968)
Date: Sept. 6, 2018 · CIK: 0000806968 · Accession: 0001193125-18-268154
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38303
Referenced dates: August 27, 2018, July 24, 2018
Letter
Securities and Exchange Commission Division of Corporation Finance Re: WPP plc Form 20-F for the Fiscal Year Ended December 31, 2017 Filed April 30, 2018 File No. 001-38303
Dear Mr. Pacho:
On behalf of WPP plc (the “Company”), this letter responds to the comment received from the Commission in a letter dated August 27, 2018 (“Comment Letter No. 2”). For ease of reference in this letter, the Commission’s comment contained in Comment Letter No. 2 is reproduced in bold in this letter, and the corresponding response of the Company is shown below such comment.
1. We note your response to comment 2 in our letter dated July 24, 2018. You state regarding Memac and Mindshare Lebanon that the Syrian contacts did not involve government clients. You make no such statement regarding the services provided in Syria by JWT LL. Please clarify for us whether JWT provided advertising services to Syrian government clients and, if so, describe the advertising services provided.
JWT Limited Liability, a Syrian company, did not provide advertising services to Syrian government clients in 2015, 2016, 2017 or to date in 2018.
* * * *
On behalf of the Company we acknowledge that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
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 CORRESP Direct Dial: 212.468.4944 Email: rnorton@dglaw.com September 6, 2018 Carlos Pacho Senior Assistant Chief Accountant 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, 2017 Filed April 30, 2018 File No. 001-38303 Dear Mr. Pacho: On behalf of WPP plc (the “Company”), this letter responds to the comment received from the Commission in a letter dated August 27, 2018 (“Comment Letter No. 2”). For ease of reference in this letter, the Commission’s comment contained in Comment Letter No. 2 is reproduced in bold in this letter, and the corresponding response of the Company is shown below such comment. 1. We note your response to comment 2 in our letter dated July 24, 2018. You state regarding Memac and Mindshare Lebanon that the Syrian contacts did not involve government clients. You make no such statement regarding the services provided in Syria by JWT LL. Please clarify for us whether JWT provided advertising services to Syrian government clients and, if so, describe the advertising services provided. JWT Limited Liability, a Syrian company, did not provide advertising services to Syrian government clients in 2015, 2016, 2017 or to date in 2018. * * * * On behalf of the Company we acknowledge that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. 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 Cc: Andrea Harris, Esq.