SEC Comment Letter for AMAZON COM (AMZN) — Dec 10, 2007
AMAZON COM INC
Date: Dec. 10, 2007 · CIK: 0001018724 · Accession: 0000000000-07-059756
AI Filing Summary & Sentiment
Referenced dates: August 21, 2007, September 21, 2007
Letter
December 6, 2007 By U.S. Mail and facsim ile to (206) 266-7010 Jeffrey P. Bezos Chairman, President and Chief Executive Officer Amazon.com, Inc. 1200 12th Avenue South, Suite 1200 Seattle, WA 98144-2734
Re: Amazon.com, Inc. Definitive 14A Filed April 27, 2007 File No. 0-22513
Dear Mr. Bezos:
We have reviewed your response letter dated September 21, 2007 and have the following comments. Please respond to our comments by December 20, 2007 or tell us by that time when you will provide us with a response. 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.
Compensation Discussion and Analysis, page 13 1. We note your response to comment 6 in our letter dated August 21, 2007. Please identify all companies against which you benchmark total compensation or any material element of compensation. See Item 402(b)(2)(xiv) of Regulation S-K.
Certain Relationships and Relate d Person Transactions, page 21 2. We note your response to comment 10 in our letter dated August 21, 2007 and reissue that comment. In addition to the disclosure you have undertaken to provide, please disclose the identity of the employee who shares the same household as Brian Valentine and the iden tity of the brothers of Kal Raman.
Jeffrey P. Bezos Amazon.com, Inc. December 6, 2007 Page 2 Please contact me at (202) 551-3238 with any questions.
S i n c e r e l y ,
Ellie Quarles Special Counsel
cc: L. Michelle Wilson Senior Vice President, General Counsel and Secretary
Show Raw Text
Mail Stop 3561
December 6, 2007
By U.S. Mail and facsim ile to (206) 266-7010
Jeffrey P. Bezos
Chairman, President and Chief Executive Officer
Amazon.com, Inc.
1200 12th Avenue South, Suite 1200
Seattle, WA 98144-2734
Re: Amazon.com, Inc.
Definitive 14A
Filed April 27, 2007
File No. 0-22513
Dear Mr. Bezos:
We have reviewed your response letter dated September 21, 2007 and have the
following comments. Please respond to our comments by December 20, 2007 or tell us
by that time when you will provide us with a response. 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.
Compensation Discussion and Analysis, page 13
1. We note your response to comment 6 in our letter dated August 21, 2007. Please
identify all companies against which you benchmark total compensation or any
material element of compensation. See Item 402(b)(2)(xiv) of Regulation S-K.
Certain Relationships and Relate d Person Transactions, page 21
2. We note your response to comment 10 in our letter dated August 21, 2007 and
reissue that comment. In addition to the disclosure you have undertaken to
provide, please disclose the identity of the employee who shares the same
household as Brian Valentine and the iden tity of the brothers of Kal Raman.
Jeffrey P. Bezos
Amazon.com, Inc.
December 6, 2007 Page 2
Please contact me at (202) 551-3238 with any questions.
S i n c e r e l y ,
Ellie Quarles
Special Counsel
cc: L. Michelle Wilson
Senior Vice President, General Counsel and
Secretary