SEC Comment Letter for TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686) (TEVA) — Apr 19, 2013
TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686)
Date: April 19, 2013 · CIK: 0000818686 · Accession: 0000000000-13-021267
AI Filing Summary & Sentiment
File numbers found in text: 001-16174
Letter
April 19, 201 3 Via E -mail Mr. Eyal Desheh Chief Financial Officer Teva Pharmaceutical Industries Limited 5 Basel Street P.O. Box 3190 Petach Tikva 49131, Israel
Re: Teva Pharmaceuticals Industries Limited Form 20-F for the Fiscal Year Ended December 31, 2012 Filed February 12 , 201 3 File No. 001-16174
Dear Mr . Desheh :
We have reviewed your March 29, 2013 response to our March 19, 2013 letter and have the follow ing comment . In our comment , we ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response . If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a lett er on EDGAR under the form type label CORRESP that key s your response to our comment .
After reviewing the information you provide in response to this comment , we may have additional comments and/or request that you amend your filing.
Notes to Consolidate d Financial Statements Note 15.d Securitization, page F -51
1. Regarding your securitized trade receivables, please provide us proposed disclosure to include in future filings that complies with ASC 860 -20-50, as applicable. In addition, include in your propo sed disclosure the amount of trade receiva bles securitized during each period presented , and the nature and amounts of items that have been netted against trade receivables and the rationale for the net presentation . In this regard, your 2011 Form 20 -F you reference securitized trade receivables of $558 million yet in your 2012 Form 20 -F you state that during 2011 and 2012 you securitized approximately $535 million (net) of your trade re ceivables.
Mr. Eyal Desheh Teva Pharmaceutical Industries Limited April 19, 201 3 Page 2
You may c ontact Dana Hartz, Staff Accountant, at (202) 551 -3648 or Lisa Vanjoske , Assistant Chief Accountant , at (202) 551-3614 if you have questions regarding t his comment . In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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April 19, 201 3 Via E -mail Mr. Eyal Desheh Chief Financial Officer Teva Pharmaceutical Industries Limited 5 Basel Street P.O. Box 3190 Petach Tikva 49131, Israel Re: Teva Pharmaceuticals Industries Limited Form 20-F for the Fiscal Year Ended December 31, 2012 Filed February 12 , 201 3 File No. 001-16174 Dear Mr . Desheh : We have reviewed your March 29, 2013 response to our March 19, 2013 letter and have the follow ing comment . In our comment , we ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response . If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a lett er on EDGAR under the form type label CORRESP that key s your response to our comment . After reviewing the information you provide in response to this comment , we may have additional comments and/or request that you amend your filing. Notes to Consolidate d Financial Statements Note 15.d Securitization, page F -51 1. Regarding your securitized trade receivables, please provide us proposed disclosure to include in future filings that complies with ASC 860 -20-50, as applicable. In addition, include in your propo sed disclosure the amount of trade receiva bles securitized during each period presented , and the nature and amounts of items that have been netted against trade receivables and the rationale for the net presentation . In this regard, your 2011 Form 20 -F you reference securitized trade receivables of $558 million yet in your 2012 Form 20 -F you state that during 2011 and 2012 you securitized approximately $535 million (net) of your trade re ceivables. Mr. Eyal Desheh Teva Pharmaceutical Industries Limited April 19, 201 3 Page 2 You may c ontact Dana Hartz, Staff Accountant, at (202) 551 -3648 or Lisa Vanjoske , Assistant Chief Accountant , at (202) 551-3614 if you have questions regarding t his comment . In this regard, do not hesitate to contact me at (202) 551 -3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant