SEC Comment Letter for HERBALIFE LTD. (HLF) (CIK 0001180262) (HLF) — May 27, 2015
HERBALIFE LTD. (HLF) (CIK 0001180262)
Date: May 27, 2015 · CIK: 0001180262 · Accession: 0000000000-15-028220
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File numbers found in text: 001-32381
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May 27 , 2015 Via E -Mail Michael Johnson Chief Executive Officer Herbalife Ltd. P.O. Box 309GT Ugland House, South Church Street Grand Cayman, Cayman Islands Re: Herbalife Ltd. Form 10-K for the Year Ended December 31, 2013 Form 10-K for the Year Ended December 31, 2014 File No. 001-32381 Dear Mr. Johnson : We have completed our review of your filings . 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 s and the company may not assert staff comments as a defense in any proceed ing 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 s to be certain that the filing s include the informa tion the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ James Lopez (for) John Reynolds Assistant Director