SEC Comment Letter for CROWN HOLDINGS, INC. (CCK) (CIK 0001219601) (CCK) — Jun 27, 2011
CROWN HOLDINGS, INC. (CCK) (CIK 0001219601)
Date: June 27, 2011 · CIK: 0001219601 · Accession: 0000000000-11-039113
AI Filing Summary & Sentiment
Reasoning
Referenced dates: June 22, 2011
Letter
June 27, 2011 Via E-mail Timothy J. Donahue Chief Financial Officer Crown Holdings, Inc. One Crown Way Philadelphia, Pennsylvania 19154 RE: Crown Holdings, Inc. Form 10-K for the Fiscal Year Ended Decem ber 31, 2010 Filed February 28, 2011 Definitive Proxy Statement on Schedule 14A Filed March 21, 2011 Form 10-Q for the Fiscal Quarter Ended March 31, 2011 Filed May 4, 2011 File No. 0-50189
Dear Mr. Donahue: We have reviewed your response letter dated June 22, 2011, and have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10-K for the Fiscal Y ear Ended December 31, 2010
K. Provision for Asbestos, page 64
1. We note your response to comment 3 in our le tter dated June 14, 2011, including the draft disclosure you intend to include in future filings. We note that your accrual consists of an amount for pending claims and an amount for fu ture asbestos-related claims. Based on the explanation provided as to w hy you are unable to estimate the amount of reasonably possible loss, it appears that the inability to reasonabl y estimate the reasonabl y possible loss in excess of accrual relates to your future asbestos-related claims rather than your pending claims. Please revise your draft disclosu re to state the amount or rang e of reasonably possible loss in excess of accrual for your pendi ng asbestos-related claims. Ot herwise, please provide an
Mr. Donahue Crown Holdings, Inc. June 27, 2011 Page 2 explanation as to why you are unable to estima te the amount or range of reasonably possible loss in excess of accrual for pending asbestos-rela ted claims. Please also confirm to us that each quarter you are not only evaluating your a ccrual but also making every effort to estimate the amount or range of reasonable possible loss in excess of accrual for both your pending asbestos-related claims and your future asbestos-related claims. Please refer to ASC 450-20-50-4 and Question 2 to ASC 450-20-S99-1 for guidance.
You may contact Tracey Houser , Staff Accountant, at (202) 551-3736, or in her absence, me at (202) 551-3769, if you have questions regard ing comments on the financial statements and related matters. Sincerely, /s/ Rufus Decker Rufus Decker Accounting Branch Chief
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June 27, 2011 Via E-mail Timothy J. Donahue Chief Financial Officer Crown Holdings, Inc. One Crown Way Philadelphia, Pennsylvania 19154 RE: Crown Holdings, Inc. Form 10-K for the Fiscal Year Ended Decem ber 31, 2010 Filed February 28, 2011 Definitive Proxy Statement on Schedule 14A Filed March 21, 2011 Form 10-Q for the Fiscal Quarter Ended March 31, 2011 Filed May 4, 2011 File No. 0-50189 Dear Mr. Donahue: We have reviewed your response letter dated June 22, 2011, and have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10-K for the Fiscal Y ear Ended December 31, 2010 K. Provision for Asbestos, page 64 1. We note your response to comment 3 in our le tter dated June 14, 2011, including the draft disclosure you intend to include in future filings. We note that your accrual consists of an amount for pending claims and an amount for fu ture asbestos-related claims. Based on the explanation provided as to w hy you are unable to estimate the amount of reasonably possible loss, it appears that the inability to reasonabl y estimate the reasonabl y possible loss in excess of accrual relates to your future asbestos-related claims rather than your pending claims. Please revise your draft disclosu re to state the amount or rang e of reasonably possible loss in excess of accrual for your pendi ng asbestos-related claims. Ot herwise, please provide an Mr. Donahue Crown Holdings, Inc. June 27, 2011 Page 2 explanation as to why you are unable to estima te the amount or range of reasonably possible loss in excess of accrual for pending asbestos-rela ted claims. Please also confirm to us that each quarter you are not only evaluating your a ccrual but also making every effort to estimate the amount or range of reasonable possible loss in excess of accrual for both your pending asbestos-related claims and your future asbestos-related claims. Please refer to ASC 450-20-50-4 and Question 2 to ASC 450-20-S99-1 for guidance. You may contact Tracey Houser , Staff Accountant, at (202) 551-3736, or in her absence, me at (202) 551-3769, if you have questions regard ing comments on the financial statements and related matters. Sincerely, /s/ Rufus Decker Rufus Decker Accounting Branch Chief