SEC Company Response from ATN International, Inc. (ATNI) (CIK 0000879585) (ATNI) — Mar 2, 2009
ATN International, Inc. (ATNI) (CIK 0000879585)
Date: March 2, 2009 · CIK: 0000879585 · Accession: 0001104659-09-013467
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12593
Referenced dates: January 21, 2009
Letter
ATLANTIC TELE-NETWORK
10 Derby Square
Salem, MA 01970
March 2,
BY EDGAR SUBMISSION
Securities and Exchange Commission
F Street, N.E.
Mail Stop 3720
Washington, D.C. 20549
Attention: Kathleen Krebs, Esq.
Reid Hopper, Esq.
RE: Atlantic Tele-Network, Inc. (the “Company”)
Form 10-K for the year ended December 31, 2007
Filed March 17, 2008
File No. 001-12593
Ladies and Gentlemen:
On behalf of Atlantic Tele-Network, Inc. (the “Company”), we would like to thank you for discussing the Company’s responses to Staff Comments Nos. 2 and 5, as set forth on the Company’s letter dated January 21, 2009 (the “Company Response Letter”).
As we discussed on February 19, 2009, the Company will in future proxy statements further emphasize the subjective, discretionary and non-formulaic nature of the Company’s compensation policies and decisions with respect to its named executive officers (the “NEOs”), as described in the Company’s proxy statement dated April 22, 2008 (the “Proxy Statement”).
In this connection, we acknowledge the Staff’s comment that the statement on page 25 of the Proxy Statement regarding the assignment of a weighing of pre-established performance goals for the Chief Executive Officer and Chief Financial Officer may in isolation appear inconsistent with the body of the disclosure emphasizing the subjective, discretionary and non-formulaic nature of the Company’s compensation policies and decisions (several excerpts of which were reproduced in the Company Response Letter). We wish to confirm with you that, notwithstanding this individual statement, the Compensation Committee in fact made its compensatory decisions for the Chief Executive Officer and Chief Financial Officer in a highly discretionary, subjective and non-formulaic manner, as we we discussed on the call. In future filings, we will redouble our efforts to avoid any individual statements that might appear in isolation (or without further explanation) to be inconsistent with this general theme and how our Compensation Committee actually makes compensatory decisions with respect to the NEOs.
We appreciate the Staff’s comments in assisting us to comply with our disclosure obligations and our efforts to provide information to investors in a manner that is as clear and helpful as we can make it be.
If you have any questions, please contact me at (978) 619-1300 ext. 401.
Very truly yours,
/s/ Michael T. Prior
Show Raw Text
CORRESP 1 filename1.htm ATLANTIC TELE-NETWORK 10 Derby Square Salem, MA 01970 March 2, 2009 BY EDGAR SUBMISSION Securities and Exchange Commission 100 F Street, N.E. Mail Stop 3720 Washington, D.C. 20549 Attention: Kathleen Krebs, Esq. Reid Hopper, Esq. RE: Atlantic Tele-Network, Inc. (the “Company”) Form 10-K for the year ended December 31, 2007 Filed March 17, 2008 File No. 001-12593 Ladies and Gentlemen: On behalf of Atlantic Tele-Network, Inc. (the “Company”), we would like to thank you for discussing the Company’s responses to Staff Comments Nos. 2 and 5, as set forth on the Company’s letter dated January 21, 2009 (the “Company Response Letter”). As we discussed on February 19, 2009, the Company will in future proxy statements further emphasize the subjective, discretionary and non-formulaic nature of the Company’s compensation policies and decisions with respect to its named executive officers (the “NEOs”), as described in the Company’s proxy statement dated April 22, 2008 (the “Proxy Statement”). In this connection, we acknowledge the Staff’s comment that the statement on page 25 of the Proxy Statement regarding the assignment of a weighing of pre-established performance goals for the Chief Executive Officer and Chief Financial Officer may in isolation appear inconsistent with the body of the disclosure emphasizing the subjective, discretionary and non-formulaic nature of the Company’s compensation policies and decisions (several excerpts of which were reproduced in the Company Response Letter). We wish to confirm with you that, notwithstanding this individual statement, the Compensation Committee in fact made its compensatory decisions for the Chief Executive Officer and Chief Financial Officer in a highly discretionary, subjective and non-formulaic manner, as we we discussed on the call. In future filings, we will redouble our efforts to avoid any individual statements that might appear in isolation (or without further explanation) to be inconsistent with this general theme and how our Compensation Committee actually makes compensatory decisions with respect to the NEOs. We appreciate the Staff’s comments in assisting us to comply with our disclosure obligations and our efforts to provide information to investors in a manner that is as clear and helpful as we can make it be. If you have any questions, please contact me at (978) 619-1300 ext. 401. Very truly yours, /s/ Michael T. Prior Michael T. Prior President and Chief Executive Officer cc: Justin D. Benincasa Douglas J. Minster Atlantic Tele-Network, Inc. Matthew J. Gardella Edwards Angell Palmer & Dodge LLP 2