SEC Comment Letter for CBRE GROUP, INC. (CBRE) (CIK 0001138118) (CBRE) — Dec 12, 2007
CBRE GROUP, INC. (CBRE) (CIK 0001138118)
Date: Dec. 12, 2007 · CIK: 0001138118 · Accession: 0000000000-07-060091
AI Filing Summary & Sentiment
Reasoning
Referenced dates: October 5, 2007
Letter
December 12, 2007 Mail Stop 3561 By U.S. Mail and facsimile to (310) 405-8925 Larry Midler Executive Vice President and General Counsel CB Richard Ellis Group Inc. 100 North Sepulveda Blvd., Suite 1050 El Segundo, CA 90245
Re: CB Richard Ellis Group Inc. Definitive 14A Filed April 24, 2007 File No. 1-32205
Dear Mr. Midler:
We have reviewed your response letter dated October 5, 2007 and have the following comment. Please respond to our comment by December 26, 2007 or tell us by that time when you will provide us with a re sponse. If the comment requests revised disclosure in future filings, please confir m in writing that you will comply with the comment in your future filings and also e xplain to us how you intend to comply. We welcome any questions you may have about our comment or any other aspect of our review. 1. We reissue comment seven from our le tter dated August 21, 2007. You have not provided a detailed analysis as to why di sclosure of the targets would result in competitive harm. You have simply stated that you believe that the specific targets are “proprietary, competitive information that should not be disclosed publicly.” Please either provide us with a detailed explanation for your conclusion that disclosure of the target s would result in co mpetitive harm or disclose such information in future filings.
Please contact me at (202) 551-3357 with any questions.
Sincerely,
Pam Howell Special Counsel
Show Raw Text
December 12, 2007 Mail Stop 3561 By U.S. Mail and facsimile to (310) 405-8925 Larry Midler Executive Vice President and General Counsel CB Richard Ellis Group Inc. 100 North Sepulveda Blvd., Suite 1050 El Segundo, CA 90245 Re: CB Richard Ellis Group Inc. Definitive 14A Filed April 24, 2007 File No. 1-32205 Dear Mr. Midler: We have reviewed your response letter dated October 5, 2007 and have the following comment. Please respond to our comment by December 26, 2007 or tell us by that time when you will provide us with a re sponse. If the comment requests revised disclosure in future filings, please confir m in writing that you will comply with the comment in your future filings and also e xplain to us how you intend to comply. We welcome any questions you may have about our comment or any other aspect of our review. 1. We reissue comment seven from our le tter dated August 21, 2007. You have not provided a detailed analysis as to why di sclosure of the targets would result in competitive harm. You have simply stated that you believe that the specific targets are “proprietary, competitive information that should not be disclosed publicly.” Please either provide us with a detailed explanation for your conclusion that disclosure of the target s would result in co mpetitive harm or disclose such information in future filings. Please contact me at (202) 551-3357 with any questions. Sincerely, Pam Howell Special Counsel