SEC Company Response from Meta Platforms, (META) — Oct 20, 2015
Meta Platforms, Inc.
Date: Oct. 20, 2015 · CIK: 0001326801 · Accession: 0001193125-15-348420
AI Filing Summary & Sentiment
File numbers found in text: 001-35551
Referenced dates: September 3, 2015
Letter
October 20, 2015
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention:
Barbara C. Jacobs, Assistant Director
Katherine Wray, Attorney-Advisor
Re:
Facebook, Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 24, 2015
File No. 001-35551
Ladies and Gentlemen:
We are submitting this letter on behalf of Facebook, Inc. (the “Company”) as a follow-up to the Company’s letter dated September 3, 2015, as well as subsequent discussions that the Company has had with the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), in which the Company responded to the comments from the Staff received by electronic mail on August 20, 2015 (the “Comment Letter”) that relate to the Company’s Definitive Proxy Statement on Schedule 14A filed with the Commission on April 24, 2015 (the “Proxy Statement”).
The Company acknowledges the Staff’s position that Item 402 of Regulation S-K requires that the cost of any personal security measures incorporated in Mr. Zuckerberg’s overall security program must be included in “All Other Compensation” for Mr. Zuckerberg in the summary compensation table, and the Company will include disclosure of such personal security costs in the “All Other Compensation” column of the summary compensation table beginning with its 2016 Annual Proxy Statement to be filed in April 2016.
* * * * * * * *
The Company acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in the Proxy Statement;
Securities and Exchange Commission
October 20, 2015
Page 2
•
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Proxy Statement; and
•
the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * * * * * * *
Securities and Exchange Commission
October 20, 2015
Page 3
Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact me at (650) 335-7631 or, in my absence, James D. Evans at (206) 389-4559.
Sincerely,
/s/ Jeffrey R. Vetter
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CORRESP 1 filename1.htm CORRESP October 20, 2015 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 Attention: Barbara C. Jacobs, Assistant Director Katherine Wray, Attorney-Advisor Re: Facebook, Inc. Definitive Proxy Statement on Schedule 14A Filed April 24, 2015 File No. 001-35551 Ladies and Gentlemen: We are submitting this letter on behalf of Facebook, Inc. (the “Company”) as a follow-up to the Company’s letter dated September 3, 2015, as well as subsequent discussions that the Company has had with the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), in which the Company responded to the comments from the Staff received by electronic mail on August 20, 2015 (the “Comment Letter”) that relate to the Company’s Definitive Proxy Statement on Schedule 14A filed with the Commission on April 24, 2015 (the “Proxy Statement”). The Company acknowledges the Staff’s position that Item 402 of Regulation S-K requires that the cost of any personal security measures incorporated in Mr. Zuckerberg’s overall security program must be included in “All Other Compensation” for Mr. Zuckerberg in the summary compensation table, and the Company will include disclosure of such personal security costs in the “All Other Compensation” column of the summary compensation table beginning with its 2016 Annual Proxy Statement to be filed in April 2016. * * * * * * * * The Company acknowledges that: • the Company is responsible for the adequacy and accuracy of the disclosure in the Proxy Statement; Securities and Exchange Commission October 20, 2015 Page 2 • Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Proxy Statement; and • the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. * * * * * * * * Securities and Exchange Commission October 20, 2015 Page 3 Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact me at (650) 335-7631 or, in my absence, James D. Evans at (206) 389-4559. Sincerely, /s/ Jeffrey R. Vetter Jeffrey R. Vetter cc: David M. Wehner, Chief Financial Officer Colin S. Stretch, Vice President, General Counsel, and Secretary David W. Kling, Deputy General Counsel Michael L. Johnson, Deputy General Counsel Facebook, Inc. James D. Evans Fenwick & West LLP