SEC Comment Letter for NOV Inc. (NOV) (CIK 0001021860) (NOV) — Dec 10, 2010
NOV Inc. (NOV) (CIK 0001021860)
Date: Dec. 10, 2010 · CIK: 0001021860 · Accession: 0000000000-10-074158
AI Filing Summary & Sentiment
Reasoning
Referenced dates: October 22, 2010, September 10, 2010
Letter
December 10, 2010
Mr. Merrill A. Miller, Jr. Chief Executive Officer National Oilwell Varco, Inc. 7909 Parkwood Drive Houston, TX 77036 Re: National Oilwell Varco, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Filed February 26, 2010 Response Letter Dated October 22, 2010 File No. 1-12317 Dear Mr. Miller: We have reviewed your filing and response le tter, and have the following comments. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments.
General
1. We note your response to comment 2 from our letter dated September 10, 2010, and your statement that you believe that certain in formation that you provided is commercially sensitive and could be harmful to you if pub licly disclosed. Please provide to us your basis for such belief. In addition, please provide to us an expanded discussion of the “various common conditions and exclusions” that you reference in your response. In that regard, please tell us the natu re of such conditions and exclusions, and provide relevant examples. 2. We note the article published by Reuters on December 6, 2010 regarding your role in the White House Oil Spill Commission’s probe of the Deepwater Horizon incident. Please tell us what consideration you gave to pr oviding disclosure rega rding your involvement in the Deepwater Horizon incident, in your fi lings. For example, and without limitation,
Mr. Merrill A. Miller, Jr. National Oilwell Varco, Inc. December 10, 2010 Page 2 please tell us what consideration you gave to providing related lega l proceeding or risk factor disclosure.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Please contact Douglas Brown at (202) 551-3265, or, in his ab sence, Laura Nicholson at (202) 551-3584 with any questions. Sincerely,
H. Roger Schwall Assistant Director
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December 10, 2010 Mr. Merrill A. Miller, Jr. Chief Executive Officer National Oilwell Varco, Inc. 7909 Parkwood Drive Houston, TX 77036 Re: National Oilwell Varco, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Filed February 26, 2010 Response Letter Dated October 22, 2010 File No. 1-12317 Dear Mr. Miller: We have reviewed your filing and response le tter, and have the following comments. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments. General 1. We note your response to comment 2 from our letter dated September 10, 2010, and your statement that you believe that certain in formation that you provided is commercially sensitive and could be harmful to you if pub licly disclosed. Please provide to us your basis for such belief. In addition, please provide to us an expanded discussion of the “various common conditions and exclusions” that you reference in your response. In that regard, please tell us the natu re of such conditions and exclusions, and provide relevant examples. 2. We note the article published by Reuters on December 6, 2010 regarding your role in the White House Oil Spill Commission’s probe of the Deepwater Horizon incident. Please tell us what consideration you gave to pr oviding disclosure rega rding your involvement in the Deepwater Horizon incident, in your fi lings. For example, and without limitation, Mr. Merrill A. Miller, Jr. National Oilwell Varco, Inc. December 10, 2010 Page 2 please tell us what consideration you gave to providing related lega l proceeding or risk factor disclosure. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Please contact Douglas Brown at (202) 551-3265, or, in his ab sence, Laura Nicholson at (202) 551-3584 with any questions. Sincerely, H. Roger Schwall Assistant Director