SEC Company Response from TIM PARTICIPACOES SA (CIK 0001066116) — Aug 29, 2005
TIM PARTICIPACOES SA (CIK 0001066116)
Date: Aug. 29, 2005 · CIK: 0001066116 · Accession: 0000950103-05-001920
AI Filing Summary & Sentiment
Referenced dates: August 18, 2005
Letter
VIA EDGAR SUBMISSION Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549
Re:
Dear Mr. Spirgel:
TIM Participações S.A. (the “Company”) has received the comments of the Staff (the “Staff”) of the Securities and Exchange Commission contained in the letter from the Staff dated August 18, 2005 (the “Comment Letter”) regarding the Company’s above-referenced filing on Form 20-F.
The Company is working expeditiously to respond to the Comment Letter and has commenced work on a letter responding to the Staff’s comments in consultation with the Company’s independent accountants (Ernst & Young LLP). However, because the Company’s accountants are concurrently assisting several other companies with their responses to similar comment letters, the Company and its accountants believe that it will require an additional fifteen business days to consider and respond fully to the Staff’s comments.
Accordingly, on behalf of the Company, we respectfully request an extension of time to respond to the Comment Letter beyond the ten business days specified therein. The Company anticipates submitting to the Staff a response on or around September 23, 2005.
We are grateful for the Staff’s assistance in this matter. Please do not hesitate to call me at (212) 450-4369 or Nicholas Kronfeld at (212) 450-4950 with any questions you may have regarding the Company’s proposed timetable for responding to the Comment Letter.
Very truly yours,
/s/ Justin Powell
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DAVIS POLK & WARDWELL
450 Lexington Avenue,
New York, New York 10017
212 450 4000
TIM Participações S.A.
August 29, 2005
VIA EDGAR SUBMISSION
Re:
TIM Participações S.A. Form 20-F for the Fiscal Year Ended December 31,
2004 Filed on June 30, 2005 (File No. 1-14491)
Mr. Larry Spirgel
Assistant Director
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Dear Mr. Spirgel:
TIM Participações S.A. (the “Company”) has received the comments of the Staff (the
“Staff”) of the Securities and Exchange Commission contained in the letter from the Staff dated August 18, 2005 (the “Comment
Letter”) regarding the Company’s above-referenced filing on Form 20-F.
The Company is working
expeditiously to respond to the Comment Letter and has commenced work on a letter
responding to the Staff’s comments in consultation with the Company’s
independent accountants (Ernst & Young LLP). However,
because the Company’s accountants are concurrently assisting several other companies
with their responses to similar comment letters,
the Company
and its accountants believe that it will require an additional fifteen
business days to consider and respond fully to the Staff’s comments.
Accordingly, on behalf of the Company, we respectfully request an extension of time to respond to the Comment Letter beyond the ten business days specified therein. The Company anticipates
submitting to the Staff a response on or around September 23, 2005.
We are grateful for the Staff’s assistance in this matter. Please do not hesitate to call me at (212) 450-4369 or Nicholas Kronfeld at (212) 450-4950 with any questions you may have
regarding the Company’s proposed timetable for responding to the Comment Letter.
Very truly yours,
/s/ Justin Powell
Justin Powell
Associate
cc:
Alvaro Pereira de Moraes
Filho
Fabiano Gallo
TIM Participações
S.A.
Nicholas Kronfeld
Davis Polk & Wardwell