SEC Comment Letter for NOVARTIS AG (NVS, NVSEF) (CIK 0001114448) (NVS) — Jun 11, 2010
NOVARTIS AG (NVS, NVSEF) (CIK 0001114448)
Date: June 11, 2010 · CIK: 0001114448 · Accession: 0000000000-10-032814
AI Filing Summary & Sentiment
File numbers found in text: 001-15024
Letter
June 11, 2010 Raymond Breu Chief Financial Officer Novartis AG Lichtstrasse 35 4056 Basel, Switzerland Re: Novartis AG Form 20-F for the Fiscal Year Ended December 31, 2009 Filed January 26, 2010 File Number: 001-15024
Dear Mr. Breu: We have reviewed your May 11, 2010 response to our April 30, 2010 letter 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 te n business days by providing the requested information, or by advising us when you will provide the requested response. Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised disclosure will look like and identify the filing in which you intend to first include it. If you do not believe a comment applies to your facts a nd circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your responses to our comments. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Item 5. Operating and Financial Review and Prospects
Item 5.A Operating Results CORE RESULTS AS DEFINED BY NOVARTIS, page 98 1. Please refer to your response to comment one. We continue to believe that it is not appropriate to present an entire non-IFRS income statement since this gives undue prominence to the non-IFRS information. Ther efore please revise your disclosure to reconcile each non-IFRS measure separately. 2. Please refer to your response to comment two. Please revise your di sclosure to include specific information on how the tax effect was calculated such as the effective tax rate and the items that the tax ra te takes into account.
Raymond Breu Novartis AG June 11, 2010 Page 2
You may contact Vanessa Robe rtson, Staff Accountant, at (202) 551-3649 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551-3614 if you have any questions regarding these comments. In this regard, do not hesitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
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June 11, 2010 Raymond Breu Chief Financial Officer Novartis AG Lichtstrasse 35 4056 Basel, Switzerland Re: Novartis AG Form 20-F for the Fiscal Year Ended December 31, 2009 Filed January 26, 2010 File Number: 001-15024 Dear Mr. Breu: We have reviewed your May 11, 2010 response to our April 30, 2010 letter 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 te n business days by providing the requested information, or by advising us when you will provide the requested response. Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised disclosure will look like and identify the filing in which you intend to first include it. If you do not believe a comment applies to your facts a nd circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your responses to our comments. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Item 5. Operating and Financial Review and Prospects Item 5.A Operating Results CORE RESULTS AS DEFINED BY NOVARTIS, page 98 1. Please refer to your response to comment one. We continue to believe that it is not appropriate to present an entire non-IFRS income statement since this gives undue prominence to the non-IFRS information. Ther efore please revise your disclosure to reconcile each non-IFRS measure separately. 2. Please refer to your response to comment two. Please revise your di sclosure to include specific information on how the tax effect was calculated such as the effective tax rate and the items that the tax ra te takes into account. Raymond Breu Novartis AG June 11, 2010 Page 2 You may contact Vanessa Robe rtson, Staff Accountant, at (202) 551-3649 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551-3614 if you have any questions regarding these comments. In this regard, do not hesitate to contact me, at (202) 551-3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant