CORRESP 1 filename1.htm sj070411correspeni
Eni S.p.A.
Sede legale in Roma
Piazzale Enrico Mattei, 1
00144 Roma
Tel. centralino: +39 06598.21
www.eni.com

 

ALESSANDRO BERNINI

 

CHIEF FINANCIAL OFFICER

 
Direct Telephone (+39)-02-52041730  
Fax (+39)-02-52041765  
   
Prot. CFO/21/2011
April 7, 2011
 
 
United States Securities and Exchange Commission
  100 F Street N.E., Stop 7010
  Washington, D.C. 20549
  Attention: Mr. H. Roger Schwall
  Assistant Director
  Division of Corporation Finance
   
Re: Eni S.p.A.  
Form 20-F for Fiscal Year Ended December 31, 2009  
Filed April 26, 2010  
File No. 001-14090  

 

Dear Mr. Schwall:
Thank you for your letter dated April 5, 2011 setting forth comments of the Staff of the Commission relating to Eni’s annual report on Form 20-F for the year ended December 31, 2009 (the "2009 Form 20-F"). The information set forth below is submitted in response to your comments. The numbered paragraphs and headings correspond to the numbered paragraphs and headings of your letter.

Form 20-F for the Fiscal Year Ended December 31, 2009

General

1. You state in your February 11, 2011, response to comment 2 in our letter dated January 24, 2011, that your production in Iran averaged 21 KBOE/d, and that this amount represents less than 10% of the overall production from the oil and gas fields you have developed in Iran. Please revise your proposed risk factor, as set forth in your responses to comment 3 in our letter dated January 24, 2011, and comment 3 in our letter dated March 22, 2011, to include this information in addition

 

 

  Capitale sociale Euro 4.005.358.876,00 i.v.
Registro Imprese di Roma, Codice fiscale 00484960588
Partita IVA 00905811006, R.E.A. Roma n. 756453
Sedi secondarie:
Via Emilia, 1 - Piazza Ezio Vanoni, 1
20097 San Donato Milanese (MI)

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  to the statement that in 2010 your production in Iran represented approximately 1% of the Eni Group’s total production.

In response to the Staff’s comment, in the Company’s annual report on form 20-F for the year ended December 31, 2010, we will revise the risk factor on Iran as requested.

 

* * *

 

If you have any questions relating to this letter, please feel free to call the undersigned at +39-02-520-41730.

Eni acknowledges that it is responsible for the adequacy and accuracy of the disclosure in its Form 20-F, that Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to its Form 20-F, and that Eni 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.

 

 

 

  Very truly yours,
   
  /s/ ALESSANDRO BERNINI
  Alessandro Bernini
  Title: Chief Financial Officer

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