SEC Comment Letter for Huntsman CORP (HUN) (CIK 0001307954) (HUN) — Jun 5, 2007
Huntsman CORP (HUN) (CIK 0001307954)
Date: June 5, 2007 · CIK: 0001307954 · Accession: 0000000000-07-027572
AI Filing Summary & Sentiment
File numbers found in text: 001-32427
Referenced dates: May 11, 2007
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE June 5, 2007 Room 7010 J. Kimo Esplin Executive Vice President and Chief Financial Officer Huntsman Corporation 500 Huntsman Way Salt Lake City, Utah 84108
Re: Huntsman Corporation Form 10-K for Year Ended December 31, 2006 File No. 001-32427
Dear Mr. Esplin:
We have reviewed your response letter dated May 11, 2007 and have the following comment. Where indicated, we think you should revi se your document. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us w ith information so we may better understand your disclosure. After reviewing this inform ation, we may raise additional comments.
Form 10-Q for the quarter ended March 31, 2007
Item 4. Controls and Procedures, page 60
1. We note that at March 31, 2007, your management determined your disclosure controls and procedures are effective a nd further noted the changes you made to your internal control over financial reporti ng as a result of the material weakness noted at December 31, 2006. Please expand your disclosure to disclose whether the company believes the material weakne ss still exists at March 31, 2007, and to explain how management has determined th at disclosure controls and procedures are now effective given the materi al weakness noted at December 31, 2006.
You may contact Melissa Rocha at (202) 551- 3854 or me at (202) 551-3355 if you have questions regarding comments on the financ ial statements and related matters.
Sincerely,
Terence O’Brien
Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
June 5, 2007
Room 7010
J. Kimo Esplin
Executive Vice President and Chief Financial Officer
Huntsman Corporation
500 Huntsman Way
Salt Lake City, Utah 84108
Re: Huntsman Corporation
Form 10-K for Year Ended December 31, 2006
File No. 001-32427
Dear Mr. Esplin:
We have reviewed your response letter dated May 11, 2007 and have the following
comment. Where indicated, we think you should revi se your document. If you disagree,
we will consider your explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as deta iled as necessary in your expl anation. In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure. After reviewing this inform ation, we may raise additional comments.
Form 10-Q for the quarter ended March 31, 2007
Item 4. Controls and Procedures, page 60
1. We note that at March 31, 2007, your management determined your disclosure controls and procedures are effective a nd further noted the changes you made to
your internal control over financial reporti ng as a result of the material weakness
noted at December 31, 2006. Please expand your disclosure to disclose whether
the company believes the material weakne ss still exists at March 31, 2007, and to
explain how management has determined th at disclosure controls and procedures
are now effective given the materi al weakness noted at December 31, 2006.
You may contact Melissa Rocha at (202) 551- 3854 or me at (202) 551-3355 if you have
questions regarding comments on the financ ial statements and related matters.
Sincerely,
Terence O’Brien
Branch Chief