SEC Comment Letter for DR REDDYS LABORATORIES LTD (RDY) (CIK 0001135951) (RDY) — Jan 18, 2005
DR REDDYS LABORATORIES LTD (RDY) (CIK 0001135951)
Date: Jan. 18, 2005 · CIK: 0001135951 · Accession: 0000000000-05-002910
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404
DIVISION OF
CORPORATION FINANCE
Mail Stop 05-07
December 28, 2004
Via U.S. Mail
G.V. Prasad
Executive Vice Chairman and Chief Executive Officer
Dr. Reddy`s Laboratories Limited
7-1-27, Ameerpet
Hyderabad, Andhra Pradesh 500 016
India
RE: Dr. Reddy`s Laboratories Limited
Form 20-F for fiscal year ended March 31, 2004
File No. 1-15182
Dear Mr. Prasad:
We have limited our review of your Form 20-F to disclosures
relating to your contacts with countries that have been identified
as state sponsors of terrorism, and will make no further review of
the Form 20-F. Our review with respect to this issue does not
preclude further review by the Assistant Director group with respect to
other issues. At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure. Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
Additional comments.
Please understand that the purpose of our review process is
To assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings. We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect of our review. Feel free to call us at the telephone numbers
listed at the end of this letter.
Form 20-F for fiscal year ended March 31, 2004
Sales, Marketing and Distribution - p.22
We note that the Company`s key emerging markets include Korea and
Iran. In light of the fact that both North Korea and Iran have
Been identified by the U.S. State Department as state sponsors of
terrorism, and are subject to economic sanctions administered by
the U.S. Treasury Department`s Office of Foreign Assets Control,
please advise us of the materiality to the Company of your current and
planned operations in Iran and, if your operations in Korea
include or will include operations in North Korea, advise us of the
materiality to the Company of your operations in that country and
give us your view as to whether those operations constitute a
material investment risk for your security holders.
We note also that similar disclosure on p.22 of the Company`s Form
20-F for the fiscal year ended March 31, 2003 identified Syria,
another country identified by the State Department as a state
sponsor of terrorism, and subject to economic sanctions administered by
OFAC, as a key focus market. Please advise us whether the Company
continues to operate in Syria and, if such operations continue,
give us your views as to the materiality of those operations to the
Company, and whether they constitute a material investment risk to
your security holders.
In preparing your response, please consider that evaluations of
materiality should not be based solely on quantitative factors,
but should include consideration of all factors that a reasonable
investor would deem important in making an investment decision.
Closing
Please understand that we may have additional comments after
We review your response to our comment. You may contact me at
(202)942- 7817 if you have any questions about the comment or our review.
Sincerely,
Cecilia Blye, Chief
Office of Global Security
Risk
cc: Jeffrey Riedler
Assistant Director
Division of Corporation Finance
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