-----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, AD8FViFMwACJPBW7Ig+OawwT5LvYB9O6+B724hqdL/nyXNrqP7NIQcilLRorU9pH gGNo26cACMz85RxEP3bEgQ== 0000000000-06-020952.txt : 20061220 0000000000-06-020952.hdr.sgml : 20061220 20060503170226 ACCESSION NUMBER: 0000000000-06-020952 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060503 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: ALCAN INC CENTRAL INDEX KEY: 0000004285 STANDARD INDUSTRIAL CLASSIFICATION: PRIMARY SMELTING & REFINING OF NONFERROUS METALS [3330] IRS NUMBER: 000000000 STATE OF INCORPORATION: A6 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 1188 SHERBROOKE ST WEST CITY: MONTREAL QUEBEC CANA STATE: A8 ZIP: 00000 BUSINESS PHONE: 5148488000 MAIL ADDRESS: STREET 1: 1188 SHERBROOKE STREET WEST CITY: MONTREAL QUEBEC CANA STATE: A8 ZIP: 00000 FORMER COMPANY: FORMER CONFORMED NAME: ALCAN ALUMINIUM LTD /NEW DATE OF NAME CHANGE: 19930519 FORMER COMPANY: FORMER CONFORMED NAME: ALUMINUM CO OF CANADA LTD DATE OF NAME CHANGE: 19870728 LETTER 1 filename1.txt May 3, 2006 Via U.S. Mail and Facsimile Travis Engen Chief Executive Officer Alcan, Inc. 1188 Sherbrooke Street West Montreal, Quebec, Canada H3A 3G2 RE: Alcan, Inc. Form 10-K for the fiscal year ended December 31, 2004 Form 10-K for the fiscal year ended December 31, 2005 Response letter dated March 1, 2006 Response letter dated April 21, 2006 File No. 1-3677 Dear Mr. Engen: We have reviewed your response letters dated March 1, 2006, and April 21, 2006, and have the following comment. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. General - You indicate in your April 21, 2006, response to our letter of March 29, 2006, that your subsidiar(ies) have provided technology and equipment to smelters indirectly owned by the Iranian Ministry of Mines, for use in the production of aluminum. You also indicate that the aluminum produced at the smelters to which you have provided technology and equipment would be of no use in any application, including any military application, unless it is substantially processed. We are aware, from publicly available sources, that aluminum has weapons applications. We note, specifically, published reports that discuss the use of aluminum tubing to house motor casings for rockets, and in certain centrifugal processes employed to produce weapons-grade uranium. Please address for us the possibility that your reputation and share value may be impacted negatively by your provision to Iran of technology and equipment necessary to the production of a product that can be used in the production of weapons. Advise us whether, to the best of your knowledge, understanding and belief, the aluminum produced at Iranian smelters is subsequently processed in such manner and to such degree as to be usable in the production of conventional, nuclear or other weapons. Please understand that we may have additional comments after we review your response to our comment. Please file your response letter on EDGAR. Please contact Jack Guggenheim at (202) 551-3523 if you have any questions about the comment or our review. You may also contact me at (202) 551-3470. Sincerely, Cecilia D. Blye, Chief Office of Global Security Risk cc: David L. McAusland Executive Vice President Alcan, Inc. P.O. Box 6090 Montreal, Quebec H3C 3A7 Canada Roger Schwall Assistant Director Division of Corporation Finance -----END PRIVACY-ENHANCED MESSAGE-----