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SEC Comment Letter for CROWN HOLDINGS, INC. (CCK) (CIK 0001219601) (CCK) — Jul 6, 2011

CROWN HOLDINGS, INC. (CCK) (CIK 0001219601)
Date: July 6, 2011 · CIK: 0001219601 · Accession: 0000000000-11-040844

Regulatory Compliance Financial Reporting Capital Structure

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Reasoning

Referenced dates: July 5, 2011

Date
July 6, 2011
Author
/s/ Rufus Decker
Form
UPLOAD
Company
CROWN HOLDINGS, INC. (CCK) (CIK 0001219601)

Letter

July 6, 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 Form 8-K File d June 14, 2011 File No. 0-50189

Dear Mr. Donahue: We have reviewed your response letter dated July 5, 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 ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Form 8-K Filed June 14, 2011

1. We note that you filed a Form 8-K on June 14, 2011, to report your entry into a sixth amendment to your credit agreement. Please file an amendment to this Form 8-K to file the sixth amendment to your credit agreemen t as a material c ontract exhibit.

Mr. Donahue Crown Holdings, Inc. July 6, 2011 Page 2 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. Please contact Hagen Gane m, Staff Attorney, at (202) 551-3330, or in his absence, Jay Ingram, Legal Branch Chief, at (202) 551-3397, with any other questions.

Sincerely,
/s/ Rufus Decker
Rufus Decker Accounting Branch Chief

Show Raw Text
July 6, 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   Form 8-K File d June 14, 2011
File No. 0-50189

Dear Mr. Donahue:
 We have reviewed your response letter dated July 5, 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 ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.                Form 8-K Filed June 14, 2011

 1. We note that you filed a Form 8-K on June  14, 2011, to report your entry into a sixth
amendment to your credit agreement.  Please file  an amendment to this Form 8-K to file the
sixth amendment to your credit agreemen t as a material c ontract exhibit.

Mr. Donahue
Crown Holdings, Inc. July 6, 2011 Page 2
 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.  Please contact Hagen Gane m, Staff Attorney, at (202) 551-3330, or in his
absence, Jay Ingram, Legal Branch Chief, at (202) 551-3397, with any other questions.

Sincerely,
   /s/ Rufus Decker
Rufus Decker Accounting Branch Chief