SEC Comment Letter for NOVARTIS AG (NVS, NVSEF) (CIK 0001114448) (NVS) — Jun 8, 2012
NOVARTIS AG (NVS, NVSEF) (CIK 0001114448)
Date: June 8, 2012 · CIK: 0001114448 · Accession: 0000000000-12-029925
AI Filing Summary & Sentiment
File numbers found in text: 001-15024
Letter
June 8 , 201 2 Via E -mail Mr. Jonathan Symonds Chief Financial Officer Novartis AG Lichtstrasse 35 4056 Basel, Switzerland
Re: Novartis AG Form 20-F for the Fiscal Year Ended December 31, 2011 Filed January 25, 201 2 File No. 001-15024
Dear M r. Symonds :
We have reviewed your May 10 , 201 2 response to our April 12, 201 2 letter and have the following comments .
Please respond to this letter within 10 business days by providing us the requested information or by advising us when you will provide the requested response. If you do not believe a comment appl ies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR unde r the form type label CORRESP that key s your response s to our comment s.
After reviewing the information provide d, 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 Factors Affecting Results of Operations Patent Expirations, Generic Competition Pressure the Industry, page 89
1. Please refer to your response to comment one. Your response does not appear to address the second part of our original commen t to include the factors that would impact the magnitude of the negative impact in your disclosure . Please provide us proposed disclosure to be included in future periodic reports that explains the factors that could change the estimate of the impact that the loss of exclusivity will have on results of operations.
Jonathan Symonds Novartis AG June 8 , 2012 Page 2
Notes to the consolidated financial statements 15. Trade receivables, page F -48
2. Please refer to your response to comment three. We believe disclosure of the information in your response would be useful to readers of your financial statements and should be made. Please confirm that, starting with your 2012 Form 20-F, you will disclose the total due, the amount past due for more than a year and the provision for Greece, Italy, Spain and Portugal separately . In addition, please confirm that you will disclose that substantially all of the trade receivables are due directly from local governments or from government -funded entities.
You may contact Vanessa Robertson, Staff Accountant, at (202) 551 -3649 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 if you have any questions regarding the comments. In this regard, do not hesitate to contact me at (202) 551 -3651.
Sincerely,
/s/ Joel Parker
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June 8 , 201 2 Via E -mail Mr. Jonathan Symonds Chief Financial Officer Novartis AG Lichtstrasse 35 4056 Basel, Switzerland Re: Novartis AG Form 20-F for the Fiscal Year Ended December 31, 2011 Filed January 25, 201 2 File No. 001-15024 Dear M r. Symonds : We have reviewed your May 10 , 201 2 response to our April 12, 201 2 letter and have the following comments . Please respond to this letter within 10 business days by providing us the requested information or by advising us when you will provide the requested response. If you do not believe a comment appl ies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR unde r the form type label CORRESP that key s your response s to our comment s. After reviewing the information provide d, 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 Factors Affecting Results of Operations Patent Expirations, Generic Competition Pressure the Industry, page 89 1. Please refer to your response to comment one. Your response does not appear to address the second part of our original commen t to include the factors that would impact the magnitude of the negative impact in your disclosure . Please provide us proposed disclosure to be included in future periodic reports that explains the factors that could change the estimate of the impact that the loss of exclusivity will have on results of operations. Jonathan Symonds Novartis AG June 8 , 2012 Page 2 Notes to the consolidated financial statements 15. Trade receivables, page F -48 2. Please refer to your response to comment three. We believe disclosure of the information in your response would be useful to readers of your financial statements and should be made. Please confirm that, starting with your 2012 Form 20-F, you will disclose the total due, the amount past due for more than a year and the provision for Greece, Italy, Spain and Portugal separately . In addition, please confirm that you will disclose that substantially all of the trade receivables are due directly from local governments or from government -funded entities. You may contact Vanessa Robertson, Staff Accountant, at (202) 551 -3649 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 if you have any questions regarding the comments. In this regard, do not hesitate to contact me at (202) 551 -3651. Sincerely, /s/ Joel Parker Joel Parker Accounting Branch Chief