Royal Philips Electronics
Executive Vice President
& Chief Financial Officer
Mr. Jeff Jaramillo
Accounting Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
100 F Street. N.E.
Washington, D.C. 20549
U.S.A.
Amsterdam, June 14, 2011
Re: | Koninklijke Philips Electronics N.V. – Form 20-F for the Fiscal Year ended |
December 31, 2010 – Filed February 18, 2011 (File No. 001-05146-01) |
Dear Mr. Jaramillo,
Thank you for your letter dated June 6, 2011 setting forth comment regarding the Form 20-F for the fiscal year ended December 31, 2010 (the “2010 Form 20-F”) of Koninklijke Philips Electronics N.V. (“Philips” or the “Company”) and the Company’s Current Report on Form 6-K dated April 18, 2011.
To facilitate your consideration of Philips’ response, we have included below the comment and have provided Philips’ response immediately following.
In our response, we have proposed to amend the wording of certain disclosures in our future filings. We are doing that to respond to the comments and not because we believe our prior filings are materially deficient or inaccurate. Accordingly, any changes in subsequent filings should not be viewed as an admission that prior disclosures were in any way deficient.
*****
Form 20-F for the Fiscal Year Ended December 31, 2010
Philips Annual Report, Exhibit 15 (B)
Group Financial Statements, page 141
Significant accounting policies, page 154
Other non-current financial assets, page 174
1. | Refer to our prior comment 2. Please revise your future filings to include the signficant information in your response, including the following: |
• | Control of the NXP shares sold were transferred to the UK pension fund, |
• | the NXP shares were legally transferred to the UK pension fund and the UK pension fund is entitled to dividends and proceeds from any future sales of the shares, and |
• | the NXP shares sold to the UK pension fund met the definition of plan assets after their transfer. |
Response:
We will revise our future filings accordingly.
*****
Please direct any questions or comments regarding this letter to me at (011) (31) 20 59 77 142. Our fax number is (011) (31) 20 59 77 140. We are available to discuss any of the foregoing with you at your convenience, and thank you again for your consideration of our response to the comments of the Staff.
Very truly yours, |
/s/ Ron Wirahadiraksa |
Ron Wirahadiraksa |
Executive Vice President and Chief Financial Officer |
Copyholders SEC Comment Letter Mr. Ron Wirahadiraksa to Mr. Jeff Jaramillo – June 10, 2011
Jay Webb
Tim Buchmiller
Geoffrey Kruczek
(Securities and Exchange Commission)
Jan van Leeuwen
Christoph Wolfsgruber
Shalene Koster
Eric P. Coutinho
Hessel Hilarides
Marnix van Ginneken
(Koninklijke Philips Electronics N.V.)
John O’Connor
(Sullivan & Cromwell LLP)
Michiel Soeting
(KPMG Accountants NV)