SEC Comment Letter for MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Jul 12, 2011
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: July 12, 2011 · CIK: 0001333274 · Accession: 0000000000-11-041955
AI Filing Summary & Sentiment
Reasoning
Letter
July 11, 2011 Via-Email Jimmy S. H. Lee, Chairman Mercer International, Inc. Suite 2840, 650 West Georgia Street Vancouver, British Columbia Canada, V6B4N8 Re: Mercer International, Inc. Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 17, 2011 Definitive Proxy Statement on Schedule 14A Filed April 20, 2011 File No. 1-51826
Dear Mr. Lee: We have reviewed your filing and have the following comments. In some of our comments, 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 comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response.
Form 10-K for fiscal year ended December 31, 2010
Part III Information Incorporated into Definitive Proxy Statement filed April 20, 2011
Compensation Discussion and Analysis, page 19
1. We note that the performance period fo r the 2008 performance incentive supplement ended with this last fiscal year; however , you have not disclosed the targets for the performance criteria. Please confirm that you will provide such disclosure in future filings. Also, please note th at this comment would also apply to future disclosure regarding the 2010 stock incentive plan to th e extent that the performance period has ended. Lastly, please confirm that you will di sclose the peer group referenced in this section in future filings. Please provide us with draft disclosure.
Jimmy S. H. Lee Mercer International, Inc. July 11, 2011 Page 2
Please contact Edwin Kim at 202-551-3297 or Pamela Howell, Special Counsel, at 202- 551-3357 with any other questions. Sincerely, /s/ Pamela Howell for
John Reynolds Assistant Director
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July 11, 2011 Via-Email Jimmy S. H. Lee, Chairman Mercer International, Inc. Suite 2840, 650 West Georgia Street Vancouver, British Columbia Canada, V6B4N8 Re: Mercer International, Inc. Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 17, 2011 Definitive Proxy Statement on Schedule 14A Filed April 20, 2011 File No. 1-51826 Dear Mr. Lee: We have reviewed your filing and have the following comments. In some of our comments, 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 comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. Form 10-K for fiscal year ended December 31, 2010 Part III Information Incorporated into Definitive Proxy Statement filed April 20, 2011 Compensation Discussion and Analysis, page 19 1. We note that the performance period fo r the 2008 performance incentive supplement ended with this last fiscal year; however , you have not disclosed the targets for the performance criteria. Please confirm that you will provide such disclosure in future filings. Also, please note th at this comment would also apply to future disclosure regarding the 2010 stock incentive plan to th e extent that the performance period has ended. Lastly, please confirm that you will di sclose the peer group referenced in this section in future filings. Please provide us with draft disclosure. Jimmy S. H. Lee Mercer International, Inc. July 11, 2011 Page 2 Please contact Edwin Kim at 202-551-3297 or Pamela Howell, Special Counsel, at 202- 551-3357 with any other questions. Sincerely, /s/ Pamela Howell for John Reynolds Assistant Director