-----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, GapvbNQ7Bkb8JIAJpF1CWMxjxugzGkI3A8iZdL8U21QmgCBkJdjKTsxfqwy7PxP/ U+6Twu0SfPOzma8ZsqDk9w== 0000947871-06-000440.txt : 20061212 0000947871-06-000440.hdr.sgml : 20061212 20060302113450 ACCESSION NUMBER: 0000947871-06-000440 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NOKIA CORP CENTRAL INDEX KEY: 0000924613 STANDARD INDUSTRIAL CLASSIFICATION: RADIO & TV BROADCASTING & COMMUNICATIONS EQUIPMENT [3663] IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: KEILALAHDENTIE 4 STREET 2: P O BOX 226 CITY: ESPOO FINLAND STATE: H9 ZIP: 00000 BUSINESS PHONE: 0358018071 MAIL ADDRESS: STREET 1: KEILALAHDENTIE 4 STREET 2: P O BOX 226 CITY: ESPOO STATE: H9 ZIP: 02150 CORRESP 1 filename1.txt [NOKIA LOGO] [GRAPHIC OMITTED] March 2, 2006 Securities and Exchange Commission Office of Global Security Risk Cecilia D. Blye, Chief 100 F Street, NE Washington, DC 20005 Nokia Corporation Form 20-F for the fiscal year ended December 31, 2004 File No. 1-13202 Dear Ms. Blye Further to our letter of January 11, 2006 responding to your letter of December 29, 2005, we wish to follow up as a matter of completeness on the disclosure included in our Form 20-F for the fiscal year ended December 31, 2005 (the "2005 Form 20-F") relating to our business activities in Iran, Syria, Libya and Sudan. Our 2005 Form 20-F has now been completed and was filed with the Commission today. We have included in Item 4.B, Business Overview, at page 34 the disclosure attached to this letter in Enclosure 1. Nokia acknowledges that - Nokia is responsible for the adequacy and accuracy of the disclosure in its filings with the SEC; - The SEC staff comments or changes to Nokia's disclosure in response to staff comments do not foreclose the SEC from taking any action with respect to Nokia's filings; and - Nokia may not assert the SEC staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. In case of additional comments, please contact Kaarina Stahlberg, Assistant General Counsel, over the e-mail at kaarina.stahlberg@nokia.com or over the phone at +358 40 728 7843. NOKIA CORPORATION /s/ Maija Torkko /s/ Kaarina Stahlberg ---------------------- ---------------------- Maija Torkko Kaarina Stahlberg Senior Vice President, Corporate Vice President, Assistant Controller General Counsel Cc: Larry Spirgel Kyle Moffatt Division of Corporation Finance Securities and Exchange Commission Nokia Corporation 2005 Form 20-F Enclosure 1 ----------- Item 4.B Business Overview Sales and Marketing As we are a global company and have sales in most countries of the world, in 2005 we also had sales to customers in Iran, Libya and Syria. Furthermore, in 2004 we had very minor sales to customers in Sudan, but none in 2005. In 2005, we sold mobile devices and accessories to customers in Iran, Libya and Syria. In addition, we sold network equipment to a customer in Iran. In 2004, we also signed a network sales contract with a customer in Libya, but that contract has not resulted in any sales by the end of 2005. In 2005, our aggregate sales to customers in Iran, Libya and Syria accounted for approximately 1.2% of our total revenue or EUR 417 million. Iran and, to a lesser extent, Syria are subject to U.S. economic sanctions that are primarily designed to implement U.S. foreign policy. -----END PRIVACY-ENHANCED MESSAGE-----