January 4, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549-3628
Attn: Pradip Bhaumik
Cecilia Blye
Re: | Superior Industries International, Inc. |
Form10-K for the Fiscal Year Ended December 25, 2016 |
Filed March 3, 2017 |
FileNo. 1-06615 |
Dear Mr. Bhaumik and Ms. Blye:
Set forth below is the response of Superior Industries International, Inc. (the “Company”) to the Staff’s letter dated December 21, 2017, regarding the Company’s Annual Report on Form10-K for the fiscal year ended December 25, 2016 (the “Form10-K”), filed with the Securities and Exchange Commission (the “Commission”) on March 3, 2017. We have addressed your December 21, 2017 letter by reproducing the comment below, in bold type, and providing the Company’s response immediately following such comment.
Form10-K for the year ended December 25, 2016
General
1. | On page 1, you state that you supply aluminum wheels for vehicles manufactured by certain automakers. We are aware of publicly available information indicating that some of the automakers you have identified sell vehicles in Sudan and/or Syria, countries which are designated as state sponsors of terrorism by the State Department and are subject to U.S. economic sanctions and/or export controls. You do not include disclosure about any contacts with Sudan or Syria. Please describe to us the nature and extent of any past, current and anticipated contacts with Sudan and Syria, whether through subsidiaries, joint ventures, customers or other direct or indirect arrangements. You should describe any products and technology you have provided into Sudan and Syria, directly or indirectly, and any agreements, arrangements or other contacts you have had with the governments of Sudan and Syria or entities they control. |
For its fiscal year ended December 25, 2016, the Company sold its products directly and exclusively to original equipment manufacturers (“OEM”) for assembly into new motor vehicles in the North American market and the Company did not sell its products to distributors or resellers for any purpose. The Company, its subsidiaries, its joint ventures
and other direct or indirect arrangements did not have any direct or indirect contacts with Sudan or Syria nor did the Company, its subsidiaries, its joint ventures or other direct or indirect arrangements provide any services, products, information or technology to the governments of Sudan or Syria or any government controlled entity or any other entity or person in those two countries. Furthermore, the Company’s corporate policies prohibited such activities. Moreover, to the Company’s knowledge, all of the Company’s OEM customers were in compliance with restrictions on the delivery of vehicles to Sudan and Syria.
If you should have any questions or comments about the response in this letter, please call me at (248)234-7198.
Sincerely, |
/s/ Joanne M. Finnorn |
Joanne M. Finnorn |
Senior Vice President, General Counsel & Corporate Secretary |
Superior Industries International, Inc. |