SEC Comment Letter for CROWN HOLDINGS, INC. (CCK) (CIK 0001219601) (CCK) — May 11, 2009
CROWN HOLDINGS, INC. (CCK) (CIK 0001219601)
Date: May 11, 2009 · CIK: 0001219601 · Accession: 0000000000-09-025201
AI Filing Summary & Sentiment
Referenced dates: April 23, 2009, March 26, 2009
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
May 11, 2009
By U.S. mail and facsimile to (215) 676-2085
Mr. Timothy J. Donahue, Executive Vice Pr esident and Chief Financial Officer
Crown Holdings, Inc. One Crown Way Philadelphia, PA 19154
RE: Crown Holdings, Inc.
Form 10-K for the fiscal year ended December 31, 2008
Filed February 27, 2009
File No. 0-50189
Dear Mr. Donahue:
We have reviewed your response letter dated April 23, 2009 and have the
following additional comment. If you disagree , we will consider your explanation as to
why our comment is inapplicable. We may or may not raise additional comments.
Form 10-K for the year ended December 31, 2008
Item 3. Legal Proceedings, page 21
1. We note your response to comment 3 in our letter dated March 26, 2009.
However, disclosure regarding the relie f sought is required under Item 103 of
Regulation S-K. We would not object if you include language similar to the last
paragraph of your response to this comment in your future disclosure. Therefore,
please provide this inform ation in future filings.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please furnish a letter that keys your
responses to our comments and provides any requested supplemental information.
Detailed response letters greatly facilitate our review. Please file your response letter on
EDGAR. Please understand that we may have additional comments after reviewing your
responses to our comments.
Mr. Timothy J. Donahue
Crown Holdings, Inc. May 11, 2009 Page 2
You may contact Jenn Do at (202) 551-3743, or me at (202) 551-3355 if you have
questions regarding comments on the financial statements and related matters. Please
contact Hagen Ganem at (202) 551-3330 or, in his absence, Brigitte Lippmann at (202)
551-3713, with any other questions.
S i n c e r e l y , T e r e n c e O ’ B r i e n B r a n c h C h i e f