SEC Comment Letter for HERBALIFE LTD. (HLF) (CIK 0001180262) (HLF) — May 20, 2016
HERBALIFE LTD. (HLF) (CIK 0001180262)
Date: May 20, 2016 · CIK: 0001180262 · Accession: 0000000000-16-077252
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File numbers found in text: 001-32381
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Mail Stop 3561 May 20 , 2016 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 Fiscal Year Ended December 31, 2015 Filed February 25, 2016 File No. 001-32381 Dear Mr. Johnson : We have completed our review of 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 assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities la ws 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 include the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Brigitte Lippmann (for) John Reynolds Assistant Director Office of Beverages, Apparel, and Mining