SEC Comment Letter for NOVARTIS AG (NVS, NVSEF) (CIK 0001114448) (NVS) — Jul 20, 2012
NOVARTIS AG (NVS, NVSEF) (CIK 0001114448)
Date: July 20, 2012 · CIK: 0001114448 · Accession: 0000000000-12-038545
AI Filing Summary & Sentiment
File numbers found in text: 001-15024
Letter
July 20, 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 June 22 , 201 2 response to our June 8 , 201 2 letter and have the following comment .
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 the comment appl ies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR un der the form type label CORRESP that key s your response to our comment.
After reviewing the information provide d, we may raise additional comments and/or request that you amend your filing .
Notes to the consolidated financial statements 15. Trade recei vables, page F -48
1. Please refer to your response to comment two. You indicate that “t hese amounts appear likely to be significant as of today .” In your May 10th response, you indicated that the “requested information is not material to investors at Dece mber 31, 2011.” Please tell us the facts, events and circumstances that have occurred since December 31, 2011 resulting in this change and why you believe the amounts are likely significant . In addition, please tell us the amount of trade receivables for Greece, Italy, Spain and Portugal and the amounts that are past due for each of these countries separately as of June 30, 2012 and whether you would consider the amounts significant .
Jonathan Symonds Novartis AG July 20, 2012 Page 2
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 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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July 20, 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 June 22 , 201 2 response to our June 8 , 201 2 letter and have the following comment . 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 the comment appl ies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR un der the form type label CORRESP that key s your response to our comment. After reviewing the information provide d, we may raise additional comments and/or request that you amend your filing . Notes to the consolidated financial statements 15. Trade recei vables, page F -48 1. Please refer to your response to comment two. You indicate that “t hese amounts appear likely to be significant as of today .” In your May 10th response, you indicated that the “requested information is not material to investors at Dece mber 31, 2011.” Please tell us the facts, events and circumstances that have occurred since December 31, 2011 resulting in this change and why you believe the amounts are likely significant . In addition, please tell us the amount of trade receivables for Greece, Italy, Spain and Portugal and the amounts that are past due for each of these countries separately as of June 30, 2012 and whether you would consider the amounts significant . Jonathan Symonds Novartis AG July 20, 2012 Page 2 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 -3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant