Correspondence 0000950103-24-016459 from SMITH & NEPHEW PLC (SNN, SNNUF) (CIK 0000845982) (SNN)
SMITH & NEPHEW PLC (SNN, SNNUF) (CIK 0000845982)
Date: Nov. 19, 2024 · CIK: 0000845982 · Accession: 0000950103-24-016459
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File numbers found in text: 001-14978
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CORRESP 1 filename1.htm November 19, 2024 By EDGAR Submission Securities and Exchange Commission 100 F. Street, N.E. Washington, D.C. 20549 Attention: Jeanne Baker Al Pavot Division of Corporation Finance, Office of Industrial Applications and Services Re: Smith & Nephew plc Form 20-F for the fiscal year ended December 31, 2023 Filed March 11, 2024 File No. 001-14978 Ladies and Gentleman, Smith & Nephew plc (“SNN” or the “Company”) is submitting this letter in response to a second set of written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated November 18, 2024 (the “Comment Letter”), on SNN’s Annual Report on Form 20-F filed with the Commission on March 11, 2024 for the fiscal year ended December 31, 2023. The Company is working expeditiously to respond to the Comment Letter and has commenced work on a letter responding to the Staff’s comments in consultation with the Company’s advisors. In order to address fully all of the points raised in the Comment Letter, the Company believes that it will require additional time to consider and respond to the Staff’s comments. Accordingly, the Company respectfully requests an extension of time to respond to the Comment Letter beyond the ten business days specified in the Comment Letter. The Company anticipates submitting to the Staff a response to the Comment Letter on or before December 16, 2024. The Company is grateful for the Staff’s assistance in this matter. Please do not hesitate to contact me with any further comments or questions. Yours faithfully, /s/ Helen Barraclough Helen Barraclough Group General Counsel and Company Secretary Cc: Connie Milonakis (Davis Polk & Wardwell London LLP)