ADDRESS: | ||||
2-1, OHTEMACHI 1-CHOME, | HEAD OFFICE | |||
CHIYODA-KU, TOKYO, | Ginza Br, J.P.O. BOX 822, | |||
JAPAN | ||||
TELEPHONE: | TOKYO 100-8631 JAPAN | FACSIMILE: | ||
03-3285-7533 | 03-3285-9819 |
Tokyo, September 10, 2010
Mr. Chris White
Branch Chief, Division of Corporate Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549-7010
U. S. A.
Re: | Mitsui & Co., Ltd. |
Form 20-F for the fiscal year ended March 31, 2010
File No. 0-09929
Dear Mr. White:
This letter relates to the comments of the Staff of the Securities and Exchange Commission (the “SEC”) in your letter dated August 27, 2010, with respect to the annual report on Form 20-F of Mitsui & Co., Ltd. for the fiscal year ended March 31, 2010 filed with the SEC on August 13, 2010.
Upon examination of the comments, we have concluded that it would require more than 10 business days to furnish appropriate responses to comments 2 and 3. Therefore, we would be grateful for the Staff’s reviewing our response to comment 1 below, ahead of our responses to the other two comments. As for comments 2 and 3, we expect to be able to submit our responses to the Staff by September 24, 2010.
Set forth below is our response to comment 1 of the Staff of the SEC. For your convenience, we have included the text of comment 1 below.
Auditor reports, page F-2 to F-4
1,
Please amend your filing to include auditor reports that include the name of the auditor and an indication that a signature has been affixed to the original audit reports.
Response
In response to the Staff’s comment 1, we will file an amendment to the Form 20-F to include the name of the auditor and an indication that a signature has been affixed to the original audit reports, together with any additional changes which may result from our future responses to comments 2 and 3. We will file such amendment as soon as all of the comments of the Staff to our annual report on Form 20-F for the year ended March 31, 2010 are cleared.
We acknowledge that:
• | we are responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | we 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. |
We also respectfully request that you copy all future correspondence in this regard to us to Investor Relations Division (Fax 81-3-3285-9819). Should you have any questions or wish to discuss the foregoing, please contact Kenichi Hori, General Manager, at 81-3-3285-7533 or k.hori@mitsui.com, or in his absence, Masao Kurihara, Senior Manager at 81-3-3285-7784 or ma.kurihara@mitsui.com. We greatly appreciate your kind understanding in this matter.
Sincerely, |
/s/ Junichi Matsumoto |
Junichi Matsumoto |
Executive Vice President and Chief Financial Officer |
cc: | Sandy Eisen |
(Division of Corporate Finance
Securities and Exchange Commission)
Yoichiro Taniguchi
Kenji Taneda
Moowi Kim
(Sullivan & Cromwell LLP)