SEC Company Response from Vale S.A. (VALE) (CIK 0000917851) (VALE) — Jan 16, 2007
Vale S.A. (VALE) (CIK 0000917851)
Date: Jan. 16, 2007 · CIK: 0000917851 · Accession: 0000903423-07-000043
AI Filing Summary & Sentiment
Letter
Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549-7410 Telecopier No.: (202) 772-9368 Re: Companhia Vale do Rio Doce – SEC Review of 2005 Form 20-F
Dear Ms. Goeken:
As indicated in a voicemail message to you and discussed with Kevin Stertzel on January 12, I am writing to provide you with a written confirmation of the expected timing of the response of our clients, Companhia Vale do Rio Doce (“CVRD”) and Vale Overseas Limited (“Vale Overseas,” and together with CVRD, the “Companies”) to the December 29, 2006 comment letter of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) on the Companies’ annual report on Form 20-F for the fiscal year ended December 31, 2005.
Due to the nature of the Staff’s comments, the complexity of certain of the issues presented and delays due to the recently ended holiday season, the Companies expect to file their response on or about January 26, 2007.
Ms. Jennifer Goeken, p. 2
If you have questions or require additional information, please do not hesitate to contact the undersigned at (212) 225-2493 or Nicolas Grabar at (212) 225-2414.
Very truly yours,
/s/ Mark A. Adams
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CORRESP
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January 16, 2007
VIA FACSIMILE
Ms. Jennifer Goeken
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-7410
Telecopier No.: (202) 772-9368
Re:
Companhia Vale do Rio Doce – SEC Review of 2005 Form 20-F
Dear Ms. Goeken:
As indicated in a voicemail message to you and discussed with Kevin Stertzel on January 12, I am writing to provide you with a written confirmation of the expected timing of the response of our clients, Companhia Vale do Rio Doce (“CVRD”) and Vale Overseas Limited (“Vale Overseas,” and together with CVRD, the “Companies”) to the December 29, 2006 comment letter of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) on the Companies’ annual report on Form 20-F for the fiscal year ended December 31, 2005.
Due to the nature of the Staff’s comments, the complexity of certain of the issues presented and delays due to the recently ended holiday season, the Companies expect to file their response on or about January 26, 2007.
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Ms. Jennifer Goeken, p. 2
If you have questions or require additional information, please do not hesitate to contact the undersigned at (212) 225-2493 or Nicolas Grabar at (212) 225-2414.
Very truly yours,
/s/ Mark A. Adams
Mark A. Adams
cc:
Kevin Stertzel, Division of Corporation Finance
Securities and Exchange Commission
Fabio de Oliveira Barbosa
Companhia Vale do Rio Doce
Nicolas Grabar
Cleary Gottlieb Steen & Hamilton LLP
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