SEC Comment Letter for IDEXX LABORATORIES (IDXX) — Jan 14, 2008
IDEXX LABORATORIES INC /DE (IDXX) (CIK 0000874716)
Date: Jan. 14, 2008 · CIK: 0000874716 · Accession: 0000000000-08-002365
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19271
Referenced dates: September 21, 2007
Letter
Mail Stop 6010
January 14, 2008
Conan R. Deady Corporate Vice President and General Counsel IDEXX Laboratories, Inc. One IDEXX Drive Westbrook, ME 04092 Re: IDEXX Laboratories, Inc. Definitive Proxy Statement Filed March 29, 2007 File No. 000-19271 Dear Mr. Deady: We have reviewed your response letter dated September 21, 2007 and have the following comments. Please respond to our comments by January 28, 2008 or tell us by that time when you will provide us with a re sponse. If the comments request revised disclosure in future filings, please confir m in writing that you will comply with the comments in your future filings and also ex plain to us how you intend to comply. We welcome any questions you may have about our comments or any other aspect of our review. 1. We have reviewed your response to comm ent 8 and are unable to concur in your conclusion that an 8% increase in base sa lary, an increase which is significantly higher than the consumer price index for th e relevant period, is not material. In your future filings, please provide discussion and analysis as to why any element of compensation paid or awarded to a ny named executive officer was materially increased or decreased.
If you have any questions, pleas e contact me at (202) 551-3635. S i n c e r e l y , T i m B u c h m i l l e r S e n i o r A t t o r n e y
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Mail Stop 6010
January 14, 2008
Conan R. Deady
Corporate Vice President and General Counsel IDEXX Laboratories, Inc. One IDEXX Drive Westbrook, ME 04092
Re: IDEXX Laboratories, Inc. Definitive Proxy Statement
Filed March 29, 2007
File No. 000-19271
Dear Mr. Deady:
We have reviewed your response letter dated September 21, 2007 and have the
following comments. Please respond to our comments by January 28, 2008 or tell us by
that time when you will provide us with a re sponse. If the comments request revised
disclosure in future filings, please confir m in writing that you will comply with the
comments in your future filings and also ex plain to us how you intend to comply. We
welcome any questions you may have about our comments or any other aspect of our review. 1. We have reviewed your response to comm ent 8 and are unable to concur in your
conclusion that an 8% increase in base sa lary, an increase which is significantly
higher than the consumer price index for th e relevant period, is not material. In
your future filings, please provide discussion and analysis as to why any element of compensation paid or awarded to a ny named executive officer was materially
increased or decreased.
If you have any questions, pleas e contact me at (202) 551-3635.
S i n c e r e l y , T i m B u c h m i l l e r S e n i o r A t t o r n e y