SEC Comment Letter for TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686) (TEVA) — Mar 17, 2011
TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686)
Date: March 17, 2011 · CIK: 0000818686 · Accession: 0000000000-11-016644
AI Filing Summary & Sentiment
Letter
March 17, 2011 Mr. Eyal Desheh Chief Financial Officer Teva Pharmaceutical Industries Limited 5 Basel Street P.O. Box 3190 Petach, Tikva 49131, Israel
Re: Teva Pharmaceutical Industries Limited Form 20-F for the Fiscal Year Ended December 31, 2009 File No . 0-16174
Dear Mr. Desheh: We have limited our review of your filing to those issues we have addressed in our comment. In our comment, we ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. Where the comment requests you to revise disclosure, the in formation you provide should show us what the revised disclosure will look like and identify the f iling in which you intend to first include it. If you do not believe the comment applies to your fa cts and circumstances, please tell us why in your response. Please furnish us a letter on E DGAR under the form type label CORRESP that keys your responses to our comment. After reviewing the information provided, we may raise additional comments and/or request that you amend your filings. Form 20-F December 31, 2009
Non-GAAP Earnings Per Share, page 68
1. Please revise to reconcile Non-GAAP earnings per share to GAAP earnings per share. Refer to Compliance and Disclosure Interp retations: Non-GAAP Fi nancial Measures - Question 102.05.
Mr. Eyal Desheh Teva Pharmaceutical Industries Limited March 17, 2011 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to 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 federa l securities laws of the United States. You may contact Lisa Vanjoske, Assistan t Chief Accountant, at (202) 551-3614 or Melissa N. Rocha, Accounting Branch Chief, at (202) 551-3854 if you have any questions regarding the comments. In this regard, do not hesitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
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March 17, 2011 Mr. Eyal Desheh Chief Financial Officer Teva Pharmaceutical Industries Limited 5 Basel Street P.O. Box 3190 Petach, Tikva 49131, Israel Re: Teva Pharmaceutical Industries Limited Form 20-F for the Fiscal Year Ended December 31, 2009 File No . 0-16174 Dear Mr. Desheh: We have limited our review of your filing to those issues we have addressed in our comment. In our comment, we ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. Where the comment requests you to revise disclosure, the in formation you provide should show us what the revised disclosure will look like and identify the f iling in which you intend to first include it. If you do not believe the comment applies to your fa cts and circumstances, please tell us why in your response. Please furnish us a letter on E DGAR under the form type label CORRESP that keys your responses to our comment. After reviewing the information provided, we may raise additional comments and/or request that you amend your filings. Form 20-F December 31, 2009 Non-GAAP Earnings Per Share, page 68 1. Please revise to reconcile Non-GAAP earnings per share to GAAP earnings per share. Refer to Compliance and Disclosure Interp retations: Non-GAAP Fi nancial Measures - Question 102.05. Mr. Eyal Desheh Teva Pharmaceutical Industries Limited March 17, 2011 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to 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 federa l securities laws of the United States. You may contact Lisa Vanjoske, Assistan t Chief Accountant, at (202) 551-3614 or Melissa N. Rocha, Accounting Branch Chief, at (202) 551-3854 if you have any questions regarding the comments. In this regard, do not hesitate to contact me, at (202) 551-3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant