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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

Regulatory Compliance Financial Reporting Internal Controls

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Reasoning

Referenced dates: April 23, 2009, March 26, 2009

Date
May 11, 2009
Author
Terence O'Brien
Form
UPLOAD
Company
CROWN HOLDINGS, INC. (CCK) (CIK 0001219601)

Letter

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

Show Raw Text
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