SEC Comment Letter for ATI INC (ATI) (CIK 0001018963) (ATI) — Jul 17, 2008
ATI INC (ATI) (CIK 0001018963)
Date: July 17, 2008 · CIK: 0001018963 · Accession: 0000000000-08-035242
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12001
Referenced dates: July 11, 2008, June 27, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 7010 July 17, 2008 Allegheny Technologies Incorporated Attention: Jon D. Walton, Executive Vice President 1000 Six PPG Place Pittsburgh, Pennsylvania 15222-5479
Re: Allegheny Technologies Incorporated Form 10-K for the Fiscal Year Ended December 31, 2007 Filed February 26, 2008 Definitive Proxy Statement Filed March 25, 2008 File No. 001-12001
Dear Mr. Walton: We have reviewed your letter dated July 11, 2008 and have the following comment. Proxy Statement for 2008 Annual Meeting of Stockholders
Grants of Plan-Based Awards for 2007, page 41 2007 Annual Incentive Plan, page 42 1. We have reviewed and carefully considered your response to comment 1 in our letter dated June 27, 2008. Please elaborate on your “competitive harm” analysis. Your July 11, 2008 letter did not provide us with sufficient information to evaluate whether you have a basis to withhold disclosure of the Other AIP Targets pursuant to Instruction 4 to Item 402(b) of Regulation S-K. For each of the Other AIP Targets, please tell us why disclosure of the target would be likely to cause you substantial competitive harm. Please be detailed and specific in your response. You may contact Dieter King at (202) 551-3338, or me at (202) 551-3765 with any questions. Sincerely, Pamela A. Long Assistant Director
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
July 17, 2008
Allegheny Technologies Incorporated
Attention: Jon D. Walton, Executive Vice President 1000 Six PPG Place Pittsburgh, Pennsylvania 15222-5479
Re: Allegheny Technologies Incorporated
Form 10-K for the Fiscal Year Ended December 31, 2007 Filed February 26, 2008 Definitive Proxy Statement Filed March 25, 2008 File No. 001-12001
Dear Mr. Walton:
We have reviewed your letter dated July 11, 2008 and have the following comment.
Proxy Statement for 2008 Annual Meeting of Stockholders
Grants of Plan-Based Awards for 2007, page 41
2007 Annual Incentive Plan, page 42
1. We have reviewed and carefully considered your response to comment 1 in our letter dated June 27, 2008. Please elaborate on your “competitive harm” analysis. Your July 11, 2008 letter did not provide us with sufficient information to evaluate whether you have a basis to withhold disclosure of the Other AIP Targets pursuant to Instruction 4 to Item 402(b) of Regulation S-K. For each of the Other AIP Targets, please tell us why
disclosure of the target would be likely to cause you substantial competitive harm. Please be detailed and specific in your response.
You may contact Dieter King at (202) 551-3338, or me at (202) 551-3765 with any
questions.
Sincerely,
Pamela A. Long Assistant Director