SEC Company Response from PORTUGAL TELECOM SGPS SA (CIK 0000944747) — Sep 21, 2004
PORTUGAL TELECOM SGPS SA (CIK 0000944747)
Date: Sept. 21, 2004 · CIK: 0000944747 · Accession: 0000950123-04-011215
AI Filing Summary & Sentiment
Letter
Office of Mergers and Acquisitions Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
Re:
Dear Mr. Edwards:
We refer to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated September 10, 2004, concerning the tender offer statements on Schedule TO-T filed by Brasilcel N.V. (“Brasilcel”), Portugal Telecom, SGPS, S.A. (“Portugal Telecom”), Telefónica Móviles, S.A. (“Telefónica Móviles”) and PT Móveis, SGPS, S.A. (“PT Móveis”) with respect to a portion of the common shares and preferred shares of Tele Leste Celular Participações S.A. and Tele Sudeste Celular Participações S.A. and the tender offer statement on Schedule TO-T filed by Telesp Celular Participações S.A., Brasilcel, Portugal Telecom, Telefónica Móviles and PT Móveis (collectively, the “Bidders”) with respect to a portion of the preferred shares of Tele Centro Oeste Celular Participações S.A. on September 1, 2004.
In addition, the undersigned Bidders hereby acknowledge that:
•
they are responsible for the adequacy and accuracy of the disclosure in their filings;
•
Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filings; and
Chris B. Edwards
•
they may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
[signature pages follow]
Very truly yours,
Brasilcel N.V.
By:
/s/ Francisco José Azevedo Padinha
Name: Francisco José Azevedo Padinha
Title: Chief Executive Officer
By:
/s/ Javier Rodríguez García
Name: Javier Rodríguez García
Title: Vice President for Technology and Networks
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
Portugal Telecom, SGPS, S.A.
By:
/s/ Miguel Horta e Costa
Name: Miguel Horta e Costa
Title: President and Chief Executive
Officer
By:
/s/ Zeinal Bava
Name: Zeinal Bava
Title: Chief Financial Officer
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
PT Móveis, SGPS, S.A.
By:
/s/ Carlos Vasconcellos Cruz
Name: Carlos Vasconcellos Cruz
Title: Chief Executive Officer
By:
/s/ Diogo Horta e Costa
Name: Diogo Horta e Costa
Title: Director
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
Telefónica Móviles, S.A.
By:
/s/ Antonio Hornedo Muguiro
Name: Antonio Hornedo Muguiro
Title: General Counsel
By:
/s/ Ernesto Lopez Mozo
Name: Ernesto Lopez Mozo
Title: Chief Financial Officer
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
Telesp Celular Participações S.A
Show Raw Text
CORRESP
1
filename1.htm
RESPONSE LETTER
September 21, 2004
Re:
Schedules TO-T filed September 1, 2004 with respect to
Tele Leste Celular Participações S.A. (File No. 5-79099),
Tele Sudeste Celular Participações S.A. (File No. 5-59155) and Tele
Centro Oeste Celular Participações S.A. (File No. 5-60699)
Chris B. Edwards
Attorney-Advisor
Office of Mergers and Acquisitions
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Dear Mr. Edwards:
We refer to the comments of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”), dated September 10, 2004, concerning
the tender offer statements on Schedule TO-T filed by Brasilcel N.V.
(“Brasilcel”), Portugal Telecom, SGPS, S.A. (“Portugal Telecom”), Telefónica
Móviles, S.A. (“Telefónica Móviles”) and PT Móveis, SGPS, S.A. (“PT Móveis”)
with respect to a portion of the common shares and preferred shares of Tele
Leste Celular Participações S.A. and Tele Sudeste Celular Participações S.A.
and the tender offer statement on Schedule TO-T filed by Telesp Celular
Participações S.A., Brasilcel, Portugal Telecom, Telefónica Móviles and PT
Móveis (collectively, the “Bidders”) with respect to a portion of the preferred
shares of Tele Centro Oeste Celular Participações S.A. on September 1, 2004.
In addition, the undersigned Bidders hereby acknowledge that:
•
they are responsible for the adequacy and
accuracy of the disclosure in their filings;
•
Staff comments or changes to disclosure in
response to Staff comments in the filings reviewed by the
Staff do not foreclose the Commission from taking any action
with respect to the filings; and
Chris B. Edwards
2
•
they may not assert Staff comments as a defense
in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.
[signature pages follow]
Very truly yours,
Brasilcel N.V.
By:
/s/ Francisco José Azevedo Padinha
Name: Francisco José Azevedo Padinha
Title: Chief Executive Officer
By:
/s/ Javier Rodríguez García
Name: Javier Rodríguez García
Title: Vice President for Technology and
Networks
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
Portugal Telecom, SGPS, S.A.
By:
/s/ Miguel Horta e Costa
Name: Miguel Horta e Costa
Title: President and Chief Executive
Officer
By:
/s/ Zeinal Bava
Name: Zeinal Bava
Title: Chief Financial Officer
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
PT Móveis, SGPS, S.A.
By:
/s/ Carlos Vasconcellos Cruz
Name: Carlos Vasconcellos Cruz
Title: Chief Executive Officer
By:
/s/ Diogo Horta e Costa
Name: Diogo Horta e Costa
Title: Director
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
Telefónica Móviles, S.A.
By:
/s/ Antonio Hornedo Muguiro
Name: Antonio Hornedo Muguiro
Title: General Counsel
By:
/s/ Ernesto Lopez Mozo
Name: Ernesto Lopez Mozo
Title: Chief Financial Officer
Signature Page to Letter to the Securities and Exchange Commission
Very truly yours,
Telesp Celular Participações S.A
By:
/s/ Francisco José Azevedo Padinha
Name: Francisco José Azevedo Padinha
Title: Chief Executive Officer
By:
/s/ Javier Rodríguez García
Name: Javier Rodríguez García
Title: Vice President for Technology and
Networks
Signature Page to Letter to the Securities and Exchange Commission