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SEC Comment Letter for CORUS GROUP PLC (CIK 0000842021) — Oct 5, 2005

CORUS GROUP PLC (CIK 0000842021)
Date: Oct. 5, 2005 · CIK: 0000842021 · Accession: 0000000000-05-051340

AI Filing Summary & Sentiment

Referenced dates: August 2, 2005, September 9, 2005

Date
October 5, 2005
Author
John Hartz
Form
UPLOAD
Company
CORUS GROUP PLC (CIK 0000842021)

Letter

via U.S. mail and facsimile to 011 44 20 7717 4455 David Lloyd Executive Director, Finance Corus Group plc 30 Millbank London SW1P 4WY England File No. 1-10120

RE: Corus Group plc Form 20-F for the fiscal year ended January 1, 2005 Filed March 31, 2005

Dear Mr. Lloyd:

We have reviewed your response letter dated September 9, and have the following additional comments. If you disagree, we will consider your explanation as to why our comment is inapplicable. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.

Form 20-F for the fiscal year ended January 1, 2005

Accounting Policies, pages 50-51

1. We note your response to prior comment 3 in our letter dated August 2, 2005. Based on your response, we believe it would be useful to tell readers that the most difficult accounting aspect with regard to the recognition and measurement of a rationalisation and redundancy provision is frequently whether or not the appropriate measurement criteria have been met to determine if a provision should actually be made under GAAP. If necessary you should discuss the measurement criteria.

Presentation II - Basis of Consolidation, page 89

2. We have reviewed your response to prior comment 4 in our letter dated August 2, 2005. Please provide us with additional detailed information for us to fully understand how you reached the conclusion that Corus Nederland should be consolidated under US GAAP. As you indicated in your response, consideration needs to be given to whether the existence of the Supervisory Board and its rights clearly demonstrates that you cannot invoke the appropriate control necessary for consolidation. ? Address each of the Board`s significant rights and indicate how those rights impacted your conclusion that consolidation is appropriate under US GAAP. ? By analogy to EITF 96-16, address whether the Board`s rights are protective rights or substantive participating rights. ? Tell us who is currently on the Supervisory Board and explain their relationship to Corus Group. Tell us whether the make-up of Supervisory Board impacted you conclusion regarding the appropriateness of consolidation. If so, tell us whether future changes to the make-up of the Supervisory Board could impact your conclusions regarding the appropriateness of consolidation.

* * * *

As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.

You may contact Jenn Do at (202) 551-3743, Jeanne Baker at (202) 551-3961 or me at (202) 551-3689 if you have questions regarding these comments.

Sincerely,
John Hartz
Senior Assistant Chief Accountant

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
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<FILENAME>filename1.txt
<TEXT>

October 5, 2005

via U.S. mail and facsimile to 011 44 20 7717 4455

David Lloyd
Executive Director, Finance
Corus Group plc
30 Millbank
London SW1P 4WY
England

	RE:	Corus Group plc
		Form 20-F for the fiscal year ended January 1, 2005
		Filed March 31, 2005

		File No. 1-10120

Dear Mr. Lloyd:

      We have reviewed your response letter dated September 9,
2005
and have the following additional comments.  If you disagree, we
will
consider your explanation as to why our comment is inapplicable.
In
some of our comments, we may ask you to provide us with
supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

Form 20-F for the fiscal year ended January 1, 2005

Accounting Policies, pages 50-51

	1.	We note your response to prior comment 3 in our letter
dated August 2, 2005.  Based on your response, we believe it would
be
useful to tell readers that the most difficult accounting aspect
with
regard to the recognition and measurement of a rationalisation and
redundancy provision is frequently whether or not the appropriate
measurement criteria have been met to determine if a provision
should
actually be made under GAAP.   If necessary you should discuss the
measurement criteria.

Presentation II - Basis of Consolidation, page 89

2.	We have reviewed your response to prior comment 4 in our
letter
dated August 2, 2005.  Please provide us with additional detailed
information for us to fully understand how you reached the
conclusion
that Corus Nederland should be consolidated under US GAAP.   As
you
indicated in your response, consideration needs to be given to
whether the existence of the Supervisory Board and its rights
clearly
demonstrates that you cannot invoke the appropriate control
necessary
for consolidation.
?        Address each of the Board`s significant rights and
indicate
how those rights impacted your conclusion that consolidation is
appropriate under US GAAP.
?        By analogy to EITF 96-16, address whether the Board`s
rights
are protective rights or substantive participating rights.
?       Tell us who is currently on the Supervisory Board and
explain
their relationship to Corus Group.  Tell us whether the make-up of
Supervisory Board impacted you conclusion regarding the
appropriateness of consolidation.  If so, tell us whether future
changes to the make-up of the Supervisory Board could impact your
conclusions regarding the appropriateness of consolidation.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your  responses to our comments.

      You may contact Jenn Do at (202) 551-3743, Jeanne Baker at
(202) 551-3961 or me at (202) 551-3689 if you have questions
regarding these comments.

								Sincerely,

								John Hartz
Senior Assistant Chief Accountant

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David Lloyd
Corus Group plc
October 5, 2005
Page 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>