SEC Comment Letter for ATI INC (ATI) (CIK 0001018963) (ATI) — Jun 9, 2010
ATI INC (ATI) (CIK 0001018963)
Date: June 9, 2010 · CIK: 0001018963 · Accession: 0000000000-10-032041
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 13, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631
DIVISION OF CORPORATION FINANCE
Mail Stop 4631 May 25, 2010
via U.S. mail and facsimile
Patrick Hassey, Chief Executive Officer Allegheny Technologies, Inc. 1000 Six PPG Place Pittsburgh, Pennsylvania 15222-5479 RE: Allegheny Technologies, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Filed February 25, 2010 File No. 1-12001 Dear Mr. Hassey:
We have reviewed your response letter dated April 13, 2010 and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable. Definitive Proxy Statement on Schedule 14A
General 1. We note that you do not have any disclosu re indicating that your compensation policies and practices for its employees are reasonably likely to have a material adverse effect on you. Please advise us of the basis for your conclusion under Item 402(s) of Regulation S-K that disclosu re is not necessary and describe for us the process you undertook to reach that conclusion.
* * * *
As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additional comments after review ing response to our comment. You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her absence Al Pavot at (202) 551-3738, or th e undersigned Accounting Branch Chief at (202) 551-3355 if you have questions regard ing comments on the financial statements
Mr. Hassey Allegheny Technologies, Inc. May 25, 2010 Page 2 and related matters. Please contact Chambr e Malone, Staff Attorn ey, at (202) 551-3262 with any legal related questions. Sincerely, T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
Mail Stop 4631
May 25, 2010
via U.S. mail and facsimile
Patrick Hassey, Chief Executive Officer Allegheny Technologies, Inc. 1000 Six PPG Place Pittsburgh, Pennsylvania 15222-5479
RE: Allegheny Technologies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009
Filed February 25, 2010 File No. 1-12001
Dear Mr. Hassey:
We have reviewed your response letter dated April 13, 2010 and have the
following additional comment. If you disagree, we will consider your explanation as to
why our comment is inapplicable.
Definitive Proxy Statement on Schedule 14A
General
1. We note that you do not have any disclosu re indicating that your compensation
policies and practices for its employees are reasonably likely to have a material
adverse effect on you. Please advise us of the basis for your conclusion under
Item 402(s) of Regulation S-K that disclosu re is not necessary and describe for us
the process you undertook to reach that conclusion.
* * * *
As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response. Please file your response letter on EDGAR.
Please understand that we may have additional comments after review ing response to our
comment. You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her
absence Al Pavot at (202) 551-3738, or th e undersigned Accounting Branch Chief at
(202) 551-3355 if you have questions regard ing comments on the financial statements
Mr. Hassey
Allegheny Technologies, Inc. May 25, 2010 Page 2 and related matters. Please contact Chambr e Malone, Staff Attorn ey, at (202) 551-3262
with any legal related questions.
Sincerely,
T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f