SEC Comment Letter for KAPPA HOLDING BV (CIK 0001097569) — Nov 3, 2005
KAPPA HOLDING BV (CIK 0001097569)
Date: Nov. 3, 2005 · CIK: 0001097569 · Accession: 0000000000-05-056041
AI Filing Summary & Sentiment
File numbers found in text: 333-11044
Referenced dates: October 6, 2005
Letter
November 3, 2005 Mr. H. Wagter Chief Financial Officer/Managing Director Kappa Holding B.V. Dr. Holtroplaan 5 NL-5652 XR Eindhoven The Netherlands
Re: Kappa Holding B.V. Form 20-F for Fiscal Year Ended December 31, 2004 Filed June 27, 2005 Response letter dated October 6, 2005 File No. 333-11044-02
Dear Mr. Wagter:
We have reviewed your filing and response letter and have the following comments. We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2004
Note 28. Supplemental Guarantor Footnote, page F-49
1. We have considered your response to prior comment six, where you indicate that you "will provide more detailed disclosure in future filings to explain the reconciling items that impact the guarantor subsidiaries." We continue to believe that it is necessary to provide disclosure to quantify the reconciling items from Dutch to US GAAP that impact all columns reported in the condensed consolidating financial statements reported. Please provide us with a sample of the intended disclosure you will provide to satisfy the requirements of Rule 3-10(i)(12) of Regulation S-X.
Response letter submitted via facsimile on October 6, 2005
2. Please submit the response letter under this heading in electronic format on Edgar as Correspondence, as required by Rule 101(a)(1)(iii) of Regulation S-T. This comment applies to all correspondence between you and the staff.
Closing Comments
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Jennifer Goeken at (202) 551-3721 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3683 with any other questions.
Sincerely,
Jill S. Davis
Branch Chief
Show Raw Text
<DOCUMENT>
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<TEXT>
November 3, 2005
Mr. H. Wagter
Chief Financial Officer/Managing Director
Kappa Holding B.V.
Dr. Holtroplaan 5
NL-5652 XR Eindhoven
The Netherlands
Re: Kappa Holding B.V.
Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 27, 2005
Response letter dated October 6, 2005
File No. 333-11044-02
Dear Mr. Wagter:
We have reviewed your filing and response letter and have
the
following comments. We have limited our review of your filing to
those issues we have addressed in our comments. Where indicated,
we
think you should revise your document in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary. Please be
as
detailed as necessary in your explanation. In some of our
comments,
we may ask you to provide us with information so we may better
understand your disclosure. After reviewing this information, we
may
raise additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2004
Note 28. Supplemental Guarantor Footnote, page F-49
1. We have considered your response to prior comment six, where
you
indicate that you "will provide more detailed disclosure in future
filings to explain the reconciling items that impact the guarantor
subsidiaries." We continue to believe that it is necessary to
provide disclosure to quantify the reconciling items from Dutch to
US
GAAP that impact all columns reported in the condensed
consolidating
financial statements reported. Please provide us with a sample of
the intended disclosure you will provide to satisfy the
requirements
of Rule 3-10(i)(12) of Regulation S-X.
Response letter submitted via facsimile on October 6, 2005
2. Please submit the response letter under this heading in
electronic
format on Edgar as Correspondence, as required by Rule
101(a)(1)(iii)
of Regulation S-T. This comment applies to all correspondence
between you and the staff.
Closing Comments
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
You may contact Jennifer Goeken at (202) 551-3721 if you
have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3683 with any other
questions.
Sincerely,
Jill S. Davis
Branch Chief
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Mr. H. Wagter
Kappa Holding B.V.
November 3, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
</TEXT>
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