SEC Comment Letter for AMPHENOL (APH) — May 21, 2008
AMPHENOL CORP /DE/ (APH) (CIK 0000820313)
Date: May 21, 2008 · CIK: 0000820313 · Accession: 0000000000-08-025975
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 6010 May 21, 2008 Martin H. Loeffler Chairman and Chief Executive Officer Amphenol Corporation 358 Hall Avenue Wallingford, CT 06492
Re: Amphenol Corporation Form 10-K for the Fiscal Year Ended December 31, 2007 Filed February 26, 2008 File No. 1-10879
Dear Mr. Loeffler:
We have reviewed your filing and have th e following comment. In our comment, we may ask you to provide us with info rmation so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Item 11. Executive Compensation, page 56
1. We note your response to our prior comment 2, however, we continue to believe that you should disclose the information called for in column s (c) through (e) of Item 402(d)(iii) to indicate the threshold, ta rget and maximum amounts as of the date of the initial grants. If you desi re, you may revise the column heading as described in Question 5.02 of Regul ation S-K Item 402 Compliance and Disclosure Interpretations (August 8, 2007) available at http://www.sec.gov/divisions/corpf in/guidance/execcomp402interp.htm , and clarify in a footnote to th e table in your future fi lings that the actual payout amounts are reflected in the Summary Compensation Table.
Martin H. Loeffler Amphenol Corporation May 21, 2008 Page 2
As appropriate, please respond to this co mment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comment and pr ovides any requested informa tion. Detailed cover letters greatly facilitate our review.
Please contact Staff Attorney Gabriel Eckstein at (202) 551-3 286 or me at (202) 551-3635 with any other questions.
Sincerely,
Timothy Buchmiller
Senior Attorney
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Mail Stop 6010
May 21, 2008
Martin H. Loeffler
Chairman and Chief Executive Officer
Amphenol Corporation
358 Hall Avenue
Wallingford, CT 06492
Re: Amphenol Corporation
Form 10-K for the Fiscal Year Ended December 31, 2007
Filed February 26, 2008
File No. 1-10879
Dear Mr. Loeffler:
We have reviewed your filing and have th e following comment. In our comment,
we may ask you to provide us with info rmation so we may better understand your
disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Item 11. Executive Compensation, page 56
1. We note your response to our prior comment 2, however, we continue to believe
that you should disclose the information called for in column s (c) through (e) of
Item 402(d)(iii) to indicate the threshold, ta rget and maximum amounts as of the
date of the initial grants. If you desi re, you may revise the column heading as
described in Question 5.02 of Regul ation S-K Item 402 Compliance and
Disclosure Interpretations (August 8, 2007) available at
http://www.sec.gov/divisions/corpf in/guidance/execcomp402interp.htm , and
clarify in a footnote to th e table in your future fi lings that the actual payout
amounts are reflected in the Summary Compensation Table.
Martin H. Loeffler
Amphenol Corporation
May 21, 2008 Page 2
As appropriate, please respond to this co mment within 10 business days or tell us
when you will provide us with a response. Please furnish a cover letter that keys your
response to our comment and pr ovides any requested informa tion. Detailed cover letters
greatly facilitate our review.
Please contact Staff Attorney Gabriel Eckstein at (202) 551-3 286 or me at (202)
551-3635 with any other questions.
Sincerely,
Timothy Buchmiller
Senior Attorney
cc: Edward C. Wetmore
Vice President, Secretary and General Counsel