SEC Comment Letter for CORUS GROUP PLC (CIK 0000842021) — Nov 29, 2005
CORUS GROUP PLC (CIK 0000842021)
Date: Nov. 29, 2005 · CIK: 0000842021 · Accession: 0000000000-05-059717
AI Filing Summary & Sentiment
Referenced dates: November 3, 2005, October 5, 2005
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 November 3, 2005 and have the following additional comments. If you disagree, we will consider your explanation as to why our comment is inapplicable. After reviewing this information, we may or may not raise additional comments.
Form 20-F for the fiscal year ended January 1, 2005
Presentation II - Basis of Consolidation, page 89
1. We have reviewed your response to comment 2 in our letter dated October 5, 2005. We note that your risk factor, titled "Certain business decisions concerning Corus` business require approval by the Corus Nederland Supervisory Board, a body whose composition is not wholly within the control of Corus", casts some doubt about your ability to control and, therefore, consolidate, Corus Nederland. In future filings, please expand your discussion under this risk factor or within your critical accounting policies to address how you determined that notwithstanding the rights of the Supervisory Board, you still have the ability to control Corus Nederland. In this regard, specifically address the fact that the Supervisory Board has no authority to establish or make operating and capital decisions, including the setting or approval of budgets, or powers to incur or reject the incurrence of additional indebtedness (unless these proposals include significant acquisitions and disposals).
* * * *
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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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
November 21, 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 November 3, 2005
and have the following additional comments. If you disagree, we
will
consider your explanation as to why our comment is inapplicable.
After reviewing this information, we may or may not raise
additional
comments.
Form 20-F for the fiscal year ended January 1, 2005
Presentation II - Basis of Consolidation, page 89
1. We have reviewed your response to comment 2 in our letter
dated
October 5, 2005. We note that your risk factor, titled "Certain
business decisions concerning Corus` business require approval by
the
Corus Nederland Supervisory Board, a body whose composition is not
wholly within the control of Corus", casts some doubt about your
ability to control and, therefore, consolidate, Corus Nederland.
In
future filings, please expand your discussion under this risk
factor
or within your critical accounting policies to address how you
determined that notwithstanding the rights of the Supervisory
Board,
you still have the ability to control Corus Nederland. In this
regard, specifically address the fact that the Supervisory Board
has
no authority to establish or make operating and capital decisions,
including the setting or approval of budgets, or powers to incur
or
reject the incurrence of additional indebtedness (unless these
proposals include significant acquisitions and disposals).
* * * *
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
November 21, 2005
Page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
</TEXT>
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