SEC Comment Letter for CONOCOPHILLIPS (COP) (CIK 0001163165) (COP) — Dec 23, 2013
CONOCOPHILLIPS (COP) (CIK 0001163165)
Date: Dec. 23, 2013 · CIK: 0001163165 · Accession: 0000000000-13-069797
AI Filing Summary & Sentiment
Referenced dates: November 20, 2013
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE December 23 , 2013 Via Facsimile Jeff W. Sheets Executive Vice President and Chief Financial Officer ConocoPhillips 600 North Dairy Ashford Houston, TX 77079
Re: ConocoPhillips Form 10-K for the Fiscal Year Ended December 31, 201 2 Filed February 1 9, 2013 File No. 1-32395
Dear Mr. Sheets :
We refer you to our comment letter dated November 20, 2013 regarding business contacts with Syria, Sudan and Cuba. We have completed our review of this subject matter. We remind you that our comments or changes to disclosure in response to our comments d o not foreclose the Commission from taking any action with respect to the company or the filing and 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require .
Sincerely,
/s/ Cecilia Blye
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
December 23 , 2013
Via Facsimile
Jeff W. Sheets
Executive Vice President and Chief Financial Officer
ConocoPhillips
600 North Dairy Ashford
Houston, TX 77079
Re: ConocoPhillips
Form 10-K for the Fiscal Year Ended December 31, 201 2
Filed February 1 9, 2013
File No. 1-32395
Dear Mr. Sheets :
We refer you to our comment letter dated November 20, 2013 regarding business
contacts with Syria, Sudan and Cuba. We have completed our review of this subject matter. We
remind you that our comments or changes to disclosure in response to our comments d o not
foreclose the Commission from taking any action with respect to the company or the filing and
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. We urge all
persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be
certain that the filing includes the information the Securities Exchange Act of 1934 and all
applicable rules require .
Sincerely,
/s/ Cecilia Blye
Cecilia Blye, Chief
Office of Global Security Risk
cc: Roger Schwall
Assistant Director
Division of Corporation Finance