-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, SJNnFaHm7fS+S78ok5rzdIwzl+ms6+vJ/unikBinqxLN/l8577MHqyiXTnLZi+9u IllCN7jeTbSTdDqV4jW6UQ== 0000950123-09-034040.txt : 20091013 0000950123-09-034040.hdr.sgml : 20091012 20090812160538 ACCESSION NUMBER: 0000950123-09-034040 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090812 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TENNECO INC CENTRAL INDEX KEY: 0001024725 STANDARD INDUSTRIAL CLASSIFICATION: MOTOR VEHICLE PARTS & ACCESSORIES [3714] IRS NUMBER: 760515284 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 500 NORTH FIELD DRIVE CITY: LAKE FOREST STATE: IL ZIP: 60045 BUSINESS PHONE: 847-482-50 MAIL ADDRESS: STREET 1: 500 N FIELD DR STREET 2: ROOM T 2560B CITY: LAKE FOREST STATE: IL ZIP: 60045 FORMER COMPANY: FORMER CONFORMED NAME: TENNECO AUTOMOTIVE INC DATE OF NAME CHANGE: 19991112 FORMER COMPANY: FORMER CONFORMED NAME: NEW TENNECO INC DATE OF NAME CHANGE: 19961011 CORRESP 1 filename1.htm FORM CORRESP
TENNECO INC. — letterhead
August 12, 2009
VIA EDGAR
Mr. Patrick Kuhn
Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Mail Stop 3561
Re:     Tenneco Inc.
Item 4.01 Form 8-K: Filed August 6, 2009
FILE NO. 001-12387
Dear Mr. Kuhn:
We are writing in response to your letter dated August 7, 2009, setting forth the comment of the staff of the Division of Corporation Finance (the “Staff”) on the Form 8-K of Tenneco Inc. (the “Company”) filed with the Securities and Exchange Commission on August 6, 2009. The Company’s response to the Staff’s comment (which is reproduced below in italicized text) is set forth below.
1.   Please amend your Form 8-K within the five days of the conclusion of your 2009 fiscal year audit, which appears to be the date of the intended dismissal of Deloitte & Touche LLP, as stated in the Item 4.01 Form 8-K filed on August 6, 2009. The amended Form 8-K should indicate whether there are any disagreements through that date and include an updated letter from your former auditor addressing your revised disclosure, filed as an exhibit to your amended Form 8-K.
 
    The Company acknowledges that it will file an amendment to its Form 8-K within five days of the conclusion of the Company’s 2009 fiscal year audit. The amended Form 8-K will indicate whether there are any disagreements with Deloitte & Touche LLP through that date. The amended Form 8-K will also include an updated Exhibit 16 letter from Deloitte & Touche LLP indicating whether or not it agrees with the disclosures in the amended Form 8-K.
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    The Company acknowledges that:
  •   The Company is responsible for the adequacy and accuracy of the disclosure in the filing;
 
  •   Staff comments or changes to disclosure in response to Staff comments do not foreclose the Securities and Exchange Commission from taking any action with respect to the filing; and
 
  •   The Company may not assert Staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or any person under the federal securities laws of the United States.
     Please contact the undersigned at (847) 482-5332 if you have any questions or require additional information.
         
  Sincerely,
 		  
  /s/ Kenneth R. Trammell    
  Kenneth R. Trammell    
  Executive Vice President and Chief Financial Officer   
 

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