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SEC Company Response from Seagate Technology Holdings plc (STX) (CIK 0001137789) (STX) — Nov 5, 2008

Seagate Technology Holdings plc (STX) (CIK 0001137789)
Date: Nov. 5, 2008 · CIK: 0001137789 · Accession: 0001193125-08-226094

AI Filing Summary & Sentiment

File numbers found in text: 001-31560

Referenced dates: October 31, 2008

Date
November 5, 2008
Author
/s/ David Z. Anderson
Form
CORRESP
Company
Seagate Technology Holdings plc (STX) (CIK 0001137789)

Letter

VIA EDGAR AND TELECOPIER 202-772-9210 Securities and Exchange Commission Division of Corporate Finance Re: Seagate Technology Form 10-K for the Fiscal Year Ended June 27, 2008 filed August 13, 2008 Definitive Proxy Statement on Schedule 14A filed September 19, 2008 File No. 001-31560

Dear Mr. Krikorian:

On behalf of Seagate Technology, an exempted company incorporated with limited liability under the laws of the Cayman Islands (the “Company”), we acknowledge receipt of your letter on behalf of the Staff of the Securities and Exchange Commission, dated October 31, 2008 (the “Staff’s Letter”).

As you may know, we spoke with Morgan Youngwood on November 3, 2008 regarding our request for an extension to respond to the Staff’s Letter. The Company’s legal, financial and accounting teams are carefully reviewing the Staff’s Letter and the Company needs additional time in order to prepare its response. This letter is submitted at Mr. Youngwood’s request to confirm our discussion regarding our proposal to submit a written response to the Staff’s Letter by December 5, 2008.

We trust that our proposed response timetable as set forth above is acceptable. If you have any comments or would like further information, please contact the undersigned at (831) 439-2781 or Kenneth M. Massaroni at (831) 439-2547.

Very truly yours,
/s/ David Z. Anderson

Show Raw Text
CORRESP
1
filename1.htm

Letter to the SEC

 SEAGATE TECHNOLOGY

 November 5, 2008

 VIA EDGAR AND TELECOPIER 202-772-9210

 Securities and Exchange Commission

 Division of Corporate Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Attn:
Stephen Krikorian

Morgan Youngwood

Re:
Seagate Technology

 Form 10-K for the Fiscal
Year Ended June 27, 2008 filed August 13, 2008

 Definitive Proxy Statement on Schedule 14A filed September 19, 2008

 File No. 001-31560

 Dear
Mr. Krikorian:

 On behalf of Seagate Technology, an exempted company incorporated with limited liability under the laws of the Cayman
Islands (the “Company”), we acknowledge receipt of your letter on behalf of the Staff of the Securities and Exchange Commission, dated October 31, 2008 (the “Staff’s Letter”).

 As you may know, we spoke with Morgan Youngwood on November 3, 2008 regarding our request for an extension to respond to the Staff’s Letter. The
Company’s legal, financial and accounting teams are carefully reviewing the Staff’s Letter and the Company needs additional time in order to prepare its response. This letter is submitted at Mr. Youngwood’s request to confirm our
discussion regarding our proposal to submit a written response to the Staff’s Letter by December 5, 2008.

 We trust that our
proposed response timetable as set forth above is acceptable. If you have any comments or would like further information, please contact the undersigned at (831) 439-2781 or Kenneth M. Massaroni at (831) 439-2547.

 Very truly yours,

 /s/ David Z. Anderson

 David Z. Anderson

 Principal Accounting Officer and Treasurer

cc:
William D. Watkins

    Chief Executive Officer

cc:
Patrick J. O’Malley

    Chief Financial Officer

cc:
Kenneth M. Massaroni

    Executive Vice President, General

    Counsel and Secretary

Seagate Technology