SEC Company Response from Seagate Technology Holdings plc (STX) (CIK 0001137789) (STX) — Mar 7, 2005
Seagate Technology Holdings plc (STX) (CIK 0001137789)
Date: March 7, 2005 · CIK: 0001137789 · Accession: 0001193125-05-043926
AI Filing Summary & Sentiment
File numbers found in text: 333-122149
Referenced dates: February 16, 2005
Letter
Securities and Exchange Commission Division of Corporate Finance Re: Seagate Technology Form S-3 Registration Statement Filed on January 19, 2005 File No. 333-122149
Dear Mr. Shuman:
On behalf of Seagate Technology, an exempted company incorporated with limited liability under the laws of the Cayman Islands (the “Company”), we hereby submit for filing by direct electronic transmission Pre-Effective Amendment No. 1 (“Amendment No. 1”) to Seagate Technology’s Registration Statement on Form S-3, File No. 333-122149 (the “Registration Statement”).
In addition, this letter responds to your letter dated February 16, 2005 in which you set forth the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the above-referenced Registration Statement. For the Staff’s convenience, we have reproduced, using bold text, each of the Staff’s comments in this letter and indicated our response thereto immediately following each comment.
Form S-3
Incorporation of Documents by Reference, page 1
1. Please update this section to incorporate by specific reference to the form type and filing date of all Section 13(a) reports filed subsequent to the date you initially filed your Form S-3 and prior to effectiveness.
In response to the Staff’s comment, the Company has updated the Incorporation by Reference section of Amendment No. 1.
* * *
To assist the Staff in its review, the Company is sending the Staff, via courier, five marked (without exhibits) and five clean (with exhibits) paper copies of Amendment No. 1. The marked copies are blacklined to show the changes that the Company made to the Registration Statement since its initial filing on January 19, 2005.
If you should have any questions or comments regarding this letter or Amendment No. 1, please contact the undersigned of Simpson Thacher & Bartlett LLP at (650) 251-5000.
Very truly yours,
/s/ JASON SCHENDEL
Show Raw Text
CORRESP 1 filename1.htm SEC Response Letter March 7, 2005 Securities and Exchange Commission Division of Corporate Finance 450 Fifth Street, N.W. Washington, D.C. 20549 Attn: Mark P. Shuman Branch Chief–Legal Re: Seagate Technology Form S-3 Registration Statement Filed on January 19, 2005 File No. 333-122149 Dear Mr. Shuman: On behalf of Seagate Technology, an exempted company incorporated with limited liability under the laws of the Cayman Islands (the “Company”), we hereby submit for filing by direct electronic transmission Pre-Effective Amendment No. 1 (“Amendment No. 1”) to Seagate Technology’s Registration Statement on Form S-3, File No. 333-122149 (the “Registration Statement”). In addition, this letter responds to your letter dated February 16, 2005 in which you set forth the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the above-referenced Registration Statement. For the Staff’s convenience, we have reproduced, using bold text, each of the Staff’s comments in this letter and indicated our response thereto immediately following each comment. Form S-3 Incorporation of Documents by Reference, page 1 1. Please update this section to incorporate by specific reference to the form type and filing date of all Section 13(a) reports filed subsequent to the date you initially filed your Form S-3 and prior to effectiveness. In response to the Staff’s comment, the Company has updated the Incorporation by Reference section of Amendment No. 1. * * * To assist the Staff in its review, the Company is sending the Staff, via courier, five marked (without exhibits) and five clean (with exhibits) paper copies of Amendment No. 1. The marked copies are blacklined to show the changes that the Company made to the Registration Statement since its initial filing on January 19, 2005. If you should have any questions or comments regarding this letter or Amendment No. 1, please contact the undersigned of Simpson Thacher & Bartlett LLP at (650) 251-5000. Very truly yours, /s/ JASON SCHENDEL Jason Schendel cc: William L. Hudson Executive Vice President, General Counsel and Secretary Seagate Technology