SEC Comment Letter for NOV Inc. (NOV) (CIK 0001021860) (NOV) — Mar 3, 2008
NOV Inc. (NOV) (CIK 0001021860)
Date: March 3, 2008 · CIK: 0001021860 · Accession: 0000000000-08-011102
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12317
Letter
February 25, 2008 Mail Stop 7010 By U.S. Mail and facsimile to (713) 346-7995 Dwight W. Rettig Vice President, General Counsel and Secretary National Oilwell Varco, Inc. 10000 Richmond Avenue Houston, Texas 77042-4200 Re: National Oilwell Varco, Inc. Definitive Proxy Statement on Schedule 14A Filed April 25, 2007 File No. 001-12317 Dear Mr. Rettig:
We have reviewed your January 16, 2008 response to our comments of December 18, 2007. Without more detail, we cannot agree or disagree with your conclusion that you have an appropriate basis to omit the opera ting profit targets and predetermined capital employed targets for prior, current and future fiscal years. Since you are in possession of all of the facts related to your disclosure, we have decided that we have no basis to disagree with your decision to omit this informa tion from your filing. As in all cases, we remind you that you are responsible for the adeq uacy and accuracy of the disclosure in your filings. We do not have any further comments on your filing.
If you have any further questions regardi ng our review of your filing, please call me at (202) 551-3687. Sincerely, Carmen Moncada-Terry A t t o r n e y A d v i s o r
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February 25, 2008 Mail Stop 7010 By U.S. Mail and facsimile to (713) 346-7995 Dwight W. Rettig Vice President, General Counsel and Secretary National Oilwell Varco, Inc. 10000 Richmond Avenue Houston, Texas 77042-4200 Re: National Oilwell Varco, Inc. Definitive Proxy Statement on Schedule 14A Filed April 25, 2007 File No. 001-12317 Dear Mr. Rettig: We have reviewed your January 16, 2008 response to our comments of December 18, 2007. Without more detail, we cannot agree or disagree with your conclusion that you have an appropriate basis to omit the opera ting profit targets and predetermined capital employed targets for prior, current and future fiscal years. Since you are in possession of all of the facts related to your disclosure, we have decided that we have no basis to disagree with your decision to omit this informa tion from your filing. As in all cases, we remind you that you are responsible for the adeq uacy and accuracy of the disclosure in your filings. We do not have any further comments on your filing. If you have any further questions regardi ng our review of your filing, please call me at (202) 551-3687. Sincerely, Carmen Moncada-Terry A t t o r n e y A d v i s o r