SEC Comment Letter for DEVON ENERGY (DVN) — Dec 30, 2011
DEVON ENERGY CORP/DE (DVN) (CIK 0001090012)
Date: Dec. 30, 2011 · CIK: 0001090012 · Accession: 0000000000-11-074347
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-32318
Letter
December 30, 2011 Via E-mail John Richels Chief Executive Officer Devon Energy Corporation 20 North Broadway Oklahoma City, OK 73102-8260 Re: Devon Energy Corporation Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 25, 2011 File No. 001-32318
Dear Mr. Richels: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide 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, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2010
Item 1A. Risk Factors, page 12
Insurance Does Not Cover All Risks, page 15
1. We note your disclosure in the above-captione d risk factor concer ning operational and financial risks, and your disclosure on page s 14 and 15 regarding regu latory risks related to hydraulic fracturing. If mate rial, please revise the above -captioned risk factor to address operational and financial risks associ ated with hydraulic fracturing, such as underground migration and surface spillage or mi shandling of fluids, including chemical additives.
John Richels Devon Energy Corporation December 30, 2011 Page 2
Closing Comments
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. In responding to our comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States.
Please contact Paul Monsour, Staff Attorne y, at (202) 551-3360, La ura Nicholson, Staff Attorney, at (202) 551-3584, or me at (202) 551-3740 with any questions.
Sincerely,
/s/ A.N. Parker for
H. Roger Schwall Assistant Director
Show Raw Text
December 30, 2011 Via E-mail John Richels Chief Executive Officer Devon Energy Corporation 20 North Broadway Oklahoma City, OK 73102-8260 Re: Devon Energy Corporation Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 25, 2011 File No. 001-32318 Dear Mr. Richels: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide 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, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2010 Item 1A. Risk Factors, page 12 Insurance Does Not Cover All Risks, page 15 1. We note your disclosure in the above-captione d risk factor concer ning operational and financial risks, and your disclosure on page s 14 and 15 regarding regu latory risks related to hydraulic fracturing. If mate rial, please revise the above -captioned risk factor to address operational and financial risks associ ated with hydraulic fracturing, such as underground migration and surface spillage or mi shandling of fluids, including chemical additives. John Richels Devon Energy Corporation December 30, 2011 Page 2 Closing Comments 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. In responding to our comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States. Please contact Paul Monsour, Staff Attorne y, at (202) 551-3360, La ura Nicholson, Staff Attorney, at (202) 551-3584, or me at (202) 551-3740 with any questions. Sincerely, /s/ A.N. Parker for H. Roger Schwall Assistant Director