SEC Company Response from James Hardie Industries plc (JHX, JHIUF) (CIK 0001159152) (JHX) — Mar 28, 2005
James Hardie Industries plc (JHX, JHIUF) (CIK 0001159152)
Date: March 28, 2005 · CIK: 0001159152 · Accession: 0000950137-05-003684
AI Filing Summary & Sentiment
File numbers found in text: 001-15240
Referenced dates: February 3, 2005
Letter
VIA EDGAR AND OVERNIGHT DELIVERY Securities and Exchange Commission Division of Corporation Finance Attention: Pamela A. Long Form 20-F for the fiscal year ended March 31, 2004 Form 6-K filed December 15, 2004 Form 6-K filed December 21, 2004 Form 6-K filed February 18, 2005
Dear Ms. Long:
The Staff provided comments, by letters dated February 3, 2005 and March 17, 2005 (the “Comment Letters”), regarding the following filings of James Hardie Industries N.V. (the “Company”): Form 20-F for the fiscal year ended March 31, 2004; Form 6-K filed December 15, 2004; Form 6-K filed December 21, 2004; and Form 6-K filed February 18, 2005.
In connection with responding to the comments in the Comment Letters, the Company acknowledges that:
(i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings;
(ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the United States Securities and Exchange Commission (the “Commission”) from taking any action with respect to the filings; and
Securities and Exchange Commission
March 23, 2005
Page 2
(iii) the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you need additional information, please contact me at 31 20 301 6748.
Very truly yours,
/s/ Benjamin Butterfield
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James Hardie Industries NV
The liability of members is limited
Incorporated in The Netherlands
4th floor, Atrium
Unit 04-07
Strawinskylaan 3077
1077 ZX Amsterdam
The Netherlands
Telephone: 31 20 301 6748
Facsimile: 31 20 404 2544
March 23, 2005
VIA EDGAR AND OVERNIGHT DELIVERY
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, NW
Washington, DC 20549
Attention: Pamela A. Long
Re:
James Hardie Industries N.V.
File No. 001-15240
Form 20-F for the fiscal year ended March 31, 2004
Form 6-K filed December 15, 2004
Form 6-K filed December 21, 2004
Form 6-K filed February 18, 2005
Dear Ms. Long:
The Staff provided comments, by letters dated February 3, 2005 and March 17, 2005 (the
“Comment Letters”), regarding the following filings of James Hardie Industries N.V. (the
“Company”): Form 20-F for the fiscal year ended March 31, 2004; Form 6-K filed December 15, 2004;
Form 6-K filed December 21, 2004; and Form 6-K filed February 18, 2005.
In connection with responding to the comments in the Comment Letters, the Company acknowledges
that:
(i)
the Company is responsible for the adequacy and accuracy of the
disclosure in its filings;
(ii)
Staff comments or changes to disclosure in response to Staff
comments do not foreclose the United States Securities and Exchange Commission
(the “Commission”) from taking any action with respect to the filings; and
Securities and Exchange
Commission
March 23, 2005
Page 2
(iii)
the Company may not assert Staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
If you need additional information, please contact me at 31 20 301 6748.
Very truly yours,
/s/ Benjamin Butterfield
Benjamin Butterfield
General Counsel
cc:
James Hardie Industries N.V.
Louis Gries, Chief Executive Officer
Russell Chenu, Chief Financial Officer
Meredith Hellicar, Chairman of the Board of Directors
Michael Brown, Chairman of the Audit Committee
Scott Barnett, Corporate Financial Controller
Securities and Exchange Commission
Rufus Decker
Andrew Schoeffler
Scott Watkinson
PricewaterhouseCoopers LLP
Ronald Bartlett
Gibson, Dunn & Crutcher LLP
Mark Shurtleff