SEC Comment Letter for CONOCOPHILLIPS (COP) (CIK 0001163165) (COP) — Aug 5, 2015
CONOCOPHILLIPS (COP) (CIK 0001163165)
Date: Aug. 5, 2015 · CIK: 0001163165 · Accession: 0000000000-15-040206
AI Filing Summary & Sentiment
File numbers found in text: 001-32395
Letter
August 5, 2015 Via Email Jeff W. Sheets Chief Financial Officer ConocoPhillips 600 North Dairy Ashford Houston, TX 77079
Re: ConocoPhillips Form 10-K for the Fiscal Year ended December 31, 2014 Filed February 24, 2015 File No. 001-32395
Dear Mr. Sheets:
We have completed our review of your filing. This completion relies on the assurances you provided not to make further disclosures of the "non-GAAP price normalized cash margin" metrics that were included in your filing.
We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not asse rt 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/H. Roger Schwall
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August 5, 2015
Via Email
Jeff W. Sheets
Chief Financial Officer
ConocoPhillips
600 North Dairy Ashford
Houston, TX 77079
Re: ConocoPhillips
Form 10-K for the Fiscal Year ended December 31, 2014
Filed February 24, 2015
File No. 001-32395
Dear Mr. Sheets:
We have completed our review of your filing. This completion relies on the assurances
you provided not to make further disclosures of the "non-GAAP price normalized cash margin"
metrics that were included in your filing.
We remind you that our comments or changes to disclosure in response to our comments
do not foreclose the Commission from taking any action with respect to the company or the
filing and the company may not asse rt 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/H. Roger Schwall
H. Roger Schwall
Assistant Director