-----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, GutZD2eW7S4HiaJSSn3SyiLXKESqAEOWRTAyTJK81CWpFxLMIje/zBTuVr+ksH/b KIqlfHsdn86gMV0fzG+aRw== 0001144204-08-002381.txt : 20080317 0001144204-08-002381.hdr.sgml : 20080317 20080115155748 ACCESSION NUMBER: 0001144204-08-002381 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080115 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NUCOR CORP CENTRAL INDEX KEY: 0000073309 STANDARD INDUSTRIAL CLASSIFICATION: STEEL WORKS, BLAST FURNACES ROLLING MILLS (COKE OVENS) [3312] IRS NUMBER: 131860817 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 2100 REXFORD RD CITY: CHARLOTTE STATE: NC ZIP: 28211 BUSINESS PHONE: 7043667000 MAIL ADDRESS: STREET 1: 2100 REXFORD ROAD CITY: CHARLOTTE STATE: NC ZIP: 28211 FORMER COMPANY: FORMER CONFORMED NAME: NUCLEAR CORP OF AMERICA INC DATE OF NAME CHANGE: 19680911 FORMER COMPANY: FORMER CONFORMED NAME: AZTEC MECHANICAL CONTRACTORS INC DATE OF NAME CHANGE: 19660629 CORRESP 1 filename1.htm





Mr. Timothy A. Geishecker
Senior Counsel
Mail Stop 4651
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-4561
 
Re:
Nucor Corporation
  Definitive 14A
  Filed March 26, 2007
  File No. 001-04119

Dear Mr. Geishecker:

This letter responds to your letter to Daniel R. DiMicco, Chairman and Chief Executive Officer of Nucor Corporation (“Nucor”), dated December 21, 2007 following your review of our response letter dated October 9, 2007. We have set forth below each of your comments. Nucor’s response is set forth below immediately following each of your comments.

1.
We note your response to comment number 4; however, it is unclear whether or not you benchmark. We note that you list your peer group companies. To the extent you are benchmarking compensation of your named executive officers against companies, you must identify the component companies. Please confirm you will comply with this response in future filings. Alternatively, if you are not using such surveys to benchmark compensation but rather are relying on such additional information to provide your compensation committee with general information to assist in its compensation level deliberations, please indicate such in your response letter and clarify disclosure in your future filings accordingly.

Nucor Response.

Nucor does not benchmark compensation to the peer group companies. The Compensation Committee uses national surveys as general information to assist in its compensation level deliberations. In future filings, we will disclose how compensation survey information is used to assist in the compensation committee’s deliberations regarding compensation levels.
 
Mr. Timothy A. Geishecker
January 15, 2008
Page 2
 
 
2.
We note your response to comment number 6. Please note that we are not looking for a calculation but rather how you determined and arrived at the amounts you disclose. Please confirm whether or not you base your determinations on the market, through negotiations with the named executive officers or through some other method.

Nucor Response.

The Compensation Committee reviews total compensation including post termination payments as compared to the market, using nationally recognized surveys, to ensure the levels of post termination payments are still appropriate. The post termination amounts disclosed and discussed in comment number 6 were originally put in place to address a significant gap in the market levels of total compensation.

In future filings, we will revise our narrative to discuss how we determined the appropriate benefit levels under the various circumstances disclosed.

Thank you for your attention to this matter. We hope that our responses address the issues raised in your letter and would be happy to discuss with you any remaining questions or concerns you may have. Please contact me at (704) 367-8634 should you have any questions or require further information.

Very truly yours,

 
/s/ Terry S. Lisenby
 
Terry S. Lisenby
Chief Financial Officer, Treasurer
and Executive Vice President
 
 
cc:
Victoria F. Haynes, Chairman
 
Compensation and Executive Development Committee

 
Daniel R. DiMicco, Chairman and Chief Executive Officer
 
 
 -----END PRIVACY-ENHANCED MESSAGE-----