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SEC Company Response from SMITH & NEPHEW PLC (SNN, SNNUF) (CIK 0000845982) (SNN) — Sep 26, 2005

SMITH & NEPHEW PLC (SNN, SNNUF) (CIK 0000845982)
Date: Sept. 26, 2005 · CIK: 0000845982 · Accession: 0001193125-05-191130

AI Filing Summary & Sentiment

File numbers found in text: 001-14978

Date
Sept. 26, 2005
Author
Branch Chief
Form
CORRESP
Company
SMITH & NEPHEW PLC (SNN, SNNUF) (CIK 0000845982)

Letter

VIA EDGAR SUBMISSION AND COURIER Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549 26 September 2005

Dear Ms Gohkle

Smith & Nephew plc, Form 20-F for the Year Ended 31 December 2004 Filed on 16 March 2005 (File No. 001-14978)

This letter relates to the comment letter from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated 19 August 2005 (the “Comment Letter”) regarding the above-referenced filing on Form 20-F (the “20-F”) of Smith & Nephew plc (the “Company”).

As noted in our letter of 12 September 2005, the Comment Letter was received by the Company on 12 September 2005. 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 independent accountants.

In view of the delay in receiving the Comment Letter, and 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 about 7 October 2005.

We are grateful for the Staff’s assistance in this matter. Please do not hesitate to call me, Clifford K Lomax, with comments or questions. Alternatively, please feel free to contact Julia K Cowles (44-20-7418-1336) of Davis Polk & Wardwell, the Company’s counsel.

Yours faithfully

/s/ Clifford K Lomax

Clifford K Lomax

Group Financial Controller

Copied to:

Julia K Cowles – Davis Polk & Wardwell

Show Raw Text
CORRESP
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filename1.htm

Letter of Correspondence

 Smith & Nephew plc

 15 Adam Street

London WC2N 6LA

 England

 T 44 (0) 207 401 7646

 F 44 (0) 207 960 2350

www.smith-nephew.com

 VIA EDGAR SUBMISSION
AND COURIER

 Ms Michele Gohlke

 Branch Chief

 Securities and Exchange Commission

 Division of Corporate Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 26 September 2005

 Dear Ms Gohkle

 Smith & Nephew plc, Form 20-F for the Year Ended 31 December 2004
Filed on 16 March 2005 (File No. 001-14978)

 This letter relates to the
comment letter from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated 19 August 2005 (the “Comment Letter”) regarding the above-referenced filing on Form 20-F (the
“20-F”) of Smith & Nephew plc (the “Company”).

 As
noted in our letter of 12 September 2005, the Comment Letter was received by the Company on 12 September 2005. 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 independent accountants.

 In
view of the delay in receiving the Comment Letter, and 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
about 7 October 2005.

 We are grateful for the Staff’s assistance in
this matter. Please do not hesitate to call me, Clifford K Lomax, with comments or questions. Alternatively, please feel free to contact Julia K Cowles (44-20-7418-1336) of Davis Polk & Wardwell, the Company’s counsel.

Yours faithfully

 /s/ Clifford K Lomax

Clifford K Lomax

Group Financial Controller

 Copied to:

 Julia K Cowles – Davis Polk & Wardwell