SEC Comment Letter for James Hardie Industries plc (JHX, JHIUF) (CIK 0001159152) (JHX) — Mar 26, 2008
James Hardie Industries plc (JHX, JHIUF) (CIK 0001159152)
Date: March 26, 2008 · CIK: 0001159152 · Accession: 0000000000-08-015892
AI Filing Summary & Sentiment
Referenced dates: February 29, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE VIA FACSIMILE AND U.S. MAIL March 26, 2008 Russell Chenu Chief Financial Officer James Hardie Industries N.V. Atrium 8 th Floor Strawinskylaan 3077 1077 ZX Amsterdam The Netherlands RE: James Hardie Industries N.V. Form 20-F for Fiscal Year Ended March 31, 2007 File No. 1-15240
Dear Mr. Chenu:
We have reviewed your letter dated February 29, 2008 and have the following comment. Where indicated, we think you should revise your disclosures in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unneces sary. Please be as detailed as necessary in your explanation. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requir ements and to enhance the overall disclosure in your filing. We look forw ard to working with you in these respects. We welcome any questions you may have about our comments or on a ny other aspect of our review. Feel free to call us at the phone numbers listed below.
FORM 20-F FOR THE YE AR ENDED MARCH 31, 2007
Item 5 – Operating and Financial Review and Prospects, page 47
Year Ended March 31, 2007 Compared to Year Ended March 31, 2006, page 52
1. We have read your response to comment two from our lett er dated January 31, 2008. On page 5, you indicate that net sa les from Asia Pacific Fiber Cement increased 4% from $241.8 in fiscal year 2006 to $251.7 m illion in fiscal year 2007 due to the increased sales volume a nd favorable currency exchange rate differences, partially offset by a decreased average net sales prices. In future filings, please quantify the impact of each business reason mentioned above within your discussion of Asia Pacific Fiber Cement Net Sales on a US dollar basis.
Mr. Russell Chenu March 26, 2008 Page 2 * * * *
Please respond to this comment within 10 business days, or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our comments and provides a ny requested information. Detailed letters greatly facilitate our review . Please file your response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Brigitte Lippmann, Staff Attorney, at (202) 551-3713 or, in her absence, Pamela Long, Assistant Director, at (202) 551-3765 if you have any questions regarding legal matters. Please contact Erne st Greene, Staff Accountant, at (202) 551- 3733 or in his absence, Jeanne Baker, Assi stant Chief Accountant, at (202) 551-3691, if you have questions regarding comments on the financial statements and related matters. Sincerely, R u f u s D e c k e r Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
VIA FACSIMILE AND U.S. MAIL
March 26, 2008
Russell Chenu Chief Financial Officer James Hardie Industries N.V. Atrium 8
th Floor
Strawinskylaan 3077 1077 ZX Amsterdam The Netherlands
RE: James Hardie Industries N.V.
Form 20-F for Fiscal Year Ended March 31, 2007 File No. 1-15240
Dear Mr. Chenu:
We have reviewed your letter dated February 29, 2008 and have the following
comment. Where indicated, we think you should revise your disclosures in response to
these comments. If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unneces sary. Please be as detailed as necessary
in your explanation. Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requir ements and to enhance the
overall disclosure in your filing. We look forw ard to working with you in these respects.
We welcome any questions you may have about our comments or on a ny other aspect of
our review. Feel free to call us at the phone numbers listed below.
FORM 20-F FOR THE YE AR ENDED MARCH 31, 2007
Item 5 – Operating and Financial Review and Prospects, page 47
Year Ended March 31, 2007 Compared to Year Ended March 31, 2006, page 52
1. We have read your response to comment two from our lett er dated January 31,
2008. On page 5, you indicate that net sa les from Asia Pacific Fiber Cement
increased 4% from $241.8 in fiscal year 2006 to $251.7 m illion in fiscal year
2007 due to the increased sales volume a nd favorable currency exchange rate
differences, partially offset by a decreased average net sales prices. In future
filings, please quantify the impact of each business reason mentioned above
within your discussion of Asia Pacific Fiber Cement Net Sales on a US dollar
basis.
Mr. Russell Chenu
March 26, 2008 Page 2
* * * *
Please respond to this comment within 10 business days, or tell us when you will
provide us with a response. Please provide us with a response letter that keys your
responses to our comments and provides a ny requested information. Detailed letters
greatly facilitate our review . Please file your response on EDGAR as a correspondence
file. Please understand that we may have additional comments after reviewing your
responses to our comments.
You may contact Brigitte Lippmann, Staff Attorney, at (202) 551-3713 or, in her
absence, Pamela Long, Assistant Director, at (202) 551-3765 if you have any questions
regarding legal matters. Please contact Erne st Greene, Staff Accountant, at (202) 551-
3733 or in his absence, Jeanne Baker, Assi stant Chief Accountant, at (202) 551-3691, if
you have questions regarding comments on the financial statements and related matters.
Sincerely, R u f u s D e c k e r
Accounting Branch Chief