SEC Comment Letter for Vale S.A. (VALE) (CIK 0000917851) (VALE) — Oct 25, 2012

Vale S.A. (VALE) (CIK 0000917851)
Date: Oct. 25, 2012 · CIK: 0000917851 · Accession: 0000000000-12-058882

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AI Filing Summary & Sentiment

Date

October 25, 2012

Author

/s/Tia L. Jenkins

Form

UPLOAD

Company

Vale S.A. (VALE) (CIK 0000917851)

Letter

October 25, 2012 Via Facsimile Mr. Murilo Pinto de Oliveira Ferreira Chief Executive Officer Vale S.A. Avenida Graça Aranha, No. 26 20030 -900 Rio de Janeiro, RJ, Brazil

Re: Vale S.A. Form 20 -F for the Fiscal Year Ended December 31, 2011 Filed April 17, 2012 File No. 001 -15030

Dear Mr. Ferreira:

We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities la ws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/Tia L. Jenkins

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October 25, 2012

Via Facsimile
Mr. Murilo Pinto de Oliveira Ferreira
Chief Executive Officer
Vale S.A.
Avenida Graça Aranha, No.  26
20030 -900 Rio de Janeiro, RJ, Brazil

 Re: Vale S.A.
  Form 20 -F for the Fiscal Year Ended December 31, 2011
Filed April 17, 2012
  File No. 001 -15030

Dear Mr. Ferreira:

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities la ws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing  to be certain that the filing  includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

/s/Tia L. Jenkins

        Tia L. Jenkins
        Senior Assistant Chief Accountant
        Office of Beverages, Apparel , and
Mining

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