 |
Sappi
Limited
|
|
Corporate
Accounting
(Reg.
no.
1936/008963/06)
PO
Box
31560
2017
Braamfontein
South
Africa
Tel
+27 (0)11
407 8111
Fax
+27 (0)11
403 8854
|
Ms
Jennifer Thompson
United
States
Securities and Exchange Commission
Division
of
Corporation Finance
100
F Street,
N.E.
Washington,
D.C.
20549
United
States of
America
January
16,
2008
Form
20-F, for the
fiscal year ended October 1, 2006, Filed December 15, 2006
Form
6-K, filed
August 8, 2007
File
No.
1-14872
Response
to the
Securities and Exchange Commission letter dated January 4, 2008
Dear
Ms
Thompson:
We,
Sappi Limited,
a company incorporated under the laws of the Republic of South Africa (the
“Company”), have set forth below the Company’s responses to the comments
received from the Staff of the Securities and Exchange Commission (the “SEC”) in
its letter dated January 4, 2008, with respect to the Company’s Form 20-F for
the fiscal year ended October 1, 2006 and the Company’s Form 6-K, furnished
August 8, 2007. The numbered paragraphs set forth below
correspond to the numbered paragraphs in the SEC staff comment
letter.
Comment
No.
1
SEC
Staff
Comments
FORM
6-K
FILED AUGUST 8, 2007
|
1.
|
We
read
in your response to our prior comment 11 that in future quarterly
results
announcements, you will adjust profit before tax to calculate operating
cash flows. While we do not object to this methodology, it is unclear
to
us why you would use a different methodology in your quarterly cash
flow
statements than you use in your annual cash flow statements. In this
regard, we note that in your annual cash flow statements, you adjust
profit after tax to calculate operating cash
flows. While we assume that this does not result in a different
subtotal for your cash generated by operations, please explain how
using a
different methodology in your interim financial statements is consistent
with the principle of presenting annual and interim financial statements
on the same basis to allow comparability. Please tell us how
you will address this comment in future
filings.
|
Directors:
E van As
(Chairman), R J Boëttger (Chief Executive Officer), D C Brink,
Dr D C Cronjé, Prof M Feldberg (USA), J E Healey (USA), Dr D
Konar,
H
C
Mamsch (Germany), Mr J D McKenzie, Mrs K R Osar (USA), Mrs B Radebe, Sir
A N R
Rudd (UK), Dr F A Sonn, M R Thompson
Secretaries:
Sappi
Management Services (Pty) Ltd (Reg. No. 1989/001134/07)
Company’s
Response to Comment 1
We
note the SEC Staff comments, and will, in future quarterly results
announcements, adjust profit after tax to calculate operating cash
flows.
If
you would like to discuss the Company’s response to the comment, please contact
the undersigned.
Yours
faithfully,
By:/s/
L.J.
Newman
_________________________________
Mr.
Laurence
Newman
Group
Financial
Controller
Sappi
Limited
Direct
telephone
number + 27 11 407 8079, direct fax number + 27 11 403
8854
Copy
to:
Craig
Wilson
United
States
Securities and Exchange Commission
Division
of
Corporation Finance
100
F Street,
N.E.
Washington,
D.C.
20549
United
States of
America
Mr.
Roeloff
Boëttger
Sappi
Limited
48
Ameshoff Street
Braamfontein
Johannesburg
2001
Republic
of South
Africa
Mr.
Mark
Thompson
Sappi
Limited
48
Ameshoff Street
Braamfontein
Johannesburg
2001
Republic
of South
Africa
Paul
Michalski,
Esq.
Cravath,
Swaine
& Moore LLP
Worldwide
Plaza
825
Eighth
Avenue
New
York, NY
10019-7475
United
States of
America
Mr.
Michael
Comber
Deloitte
&
Touche
Private
Bag
X6
Gallo
Manor
2052
Republic
of South
Africa