0000088121-13-000005.txt : 20130805
0000088121-13-000005.hdr.sgml : 20130805
20130703141204
ACCESSION NUMBER: 0000088121-13-000005
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20130703
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: SEABOARD CORP /DE/
CENTRAL INDEX KEY: 0000088121
STANDARD INDUSTRIAL CLASSIFICATION: [6221]
IRS NUMBER: 042260388
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 9000 W. 67TH STREET
CITY: SHAWNEE MISSION
STATE: KS
ZIP: 66202
BUSINESS PHONE: 9136768800
MAIL ADDRESS:
STREET 1: 9000 W. 67TH STREET
CITY: SHAWNEE MISSION
STATE: KS
ZIP: 66202
FORMER COMPANY:
FORMER CONFORMED NAME: SEABOARD ALLIED MILLING CORP
DATE OF NAME CHANGE: 19820328
FORMER COMPANY:
FORMER CONFORMED NAME: HATHAWAY BAKERIES INC
DATE OF NAME CHANGE: 19710315
CORRESP
1
filename1.txt
SEABOARD
CORPORATION
July 3, 2013
Daniel L. Gordon
Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
RE: Seaboard Corporation
Form 10-K for the year ended December 31, 2012
Filed February 27, 2013
File No. 1-03390
Dear Mr. Gordon:
We are writing in response to your letter dated June 26, 2013,
with respect to the above-referenced report filed by Seaboard
Corporation ("Seaboard" or the "Company"). Our numbered
responses to your comments correspond to the numbered comments in
your letter.
In responding to your comments, we acknowledge that:
- the Company is responsible for the adequacy and
accuracy of the disclosure in our filing with the
Commission;
- staff comments or changes to disclosure in our filing
made in response to staff comments do not foreclose the
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 Commission or any
person under the federal securities laws of the United
States.
COMMENTS AND OUR RESPONSES
Form 10-K
Contractual Obligations and Off-Balance Sheet Arrangements, page 16
Comment 1: In future filings, please revise your tabular
presentation of contractual obligations to include
your interest commitments under your interest-bearing
debt in this table, or provide textual discussion of
this obligation below the table. If you provide a
textual discussion, the discussion should quantify
the interest payments using the same time frames
stipulated in the table. Regardless of whether you
decide to include interest payments in the table or
in textual discussion below the table, you should
provide appropriate disclosure with respect to your
assumptions of your estimated variable rate interest
payments.
Response: In future filings, we will include the information as
requested.
Consolidated Statements of Comprehensive Income, page 28
Comment 2: We note that you have included dividends declared per
common share on the face of your Consolidated
Statements of Comprehensive Income. Tell us how your
disclosure complies with the guidance in FASB
ASC 260-10-45-5.
Response: In future filings, we will delete dividends declared
per common share from the face of our Consolidated
Statements of Comprehensive Income and continue to
include this information in the Notes to Consolidated
Financial Statements.
In summary, we have carefully considered the comments and views
expressed in your letter and believe your comments will improve
our future financial reporting. We believe our responses fully
respond to the comments provided, and we do not believe that
these inquires or responses indicate the existence of any
deficiencies in financial reporting controls or procedures. If
you have any questions or require any further information,
please call me at (913) 676-8833 or John Virgo at (913) 676-8936.
Very truly yours,
SEABOARD CORPORATION
/s/ Robert L. Steer
Robert L. Steer
Executive Vice President and Chief
Financial Officer