PUBLICIS GROUPE S.A.
133 AVENUE DES CHAMPS-ELYSEES
75008 PARIS, FRANCE
January 4, 2007
Securities and Exchange Commission
Mail Stop 4561
100 F. St. NE
Washington, DC 20549-3561
U.S.A.
Attention: Cecilia B. Blye, Chief
Office of Global Security Risk
Re: Publicis Groupe S.A.
Form 20-F for Fiscal Year Ended December 31, 2005
File no. 1-14736
Dear Ms. Blye:
We acknowledge receipt of your letter of December 1, 2006, asking us to describe
the extent and nature of our past, current and anticipated contacts with Syria,
whether through direct or indirect arrangements. Our response is set forth
below.
1. Publicis Groupe S.A. is the holding company for three global
advertising networks: Publicis Worldwide, Leo Burnett and Saatchi &
Saatchi.
Publicis Groupe S.A. currently has no presence in Syria, and none is
currently anticipated. One of its subsidiaries, H.C. Leo Burnett E.C.
("H&C LB"), an exempt company incorporated under the laws of Bahrain
and part of the Leo Burnett advertising network, entered into a
Technical Assistance Agreement dated October 20, 1995, with Al Cham
Company Limited ("Al Cham"), whereunder H&C LB agreed to refer its
multinational clients to Al Cham for advertising services in Syria and
to provide technical assistance to Al Cham to enable it to render
service to H&C LB's clients in a manner consistent with H&C LB's
standards of quality and service, and Al Cham agreed to pay H&C LB a
fee equal to 33% of the agency's gross revenue. At the same time Leo
Burnett Worldwide, Inc. ("LBW"), a Delaware corporation, entered into a
Trade Mark Licence Agreement with Al Cham whereunder LBW licensed Al
Cham to use the Leo Burnett trade mark in connection with its
advertising activities, and Al Cham agreed to pay LBW a fee equal to
10% of its net profit. Both the Technical Assistance Agreement and the
Trade Mark Licence
Agreement were terminated at the end of December 1998 without any fees
having been paid pursuant thereto.
H&C LB currently services its sole Syrian client, Spacetel, from its
Lebanese agency in Beirut, H&C Leo Burnett SARL Lebanon.
Similarly, Publicis Graphics S.A.R.L., an affiliate and part of the
Publicis Worldwide advertising network, provides services to Renault in
Syria from its Beirut office, and Saatchi & Saatchi Beirut SAL, an
agency in which Publicis Groupe holds a 25% interest and part of the
Saatchi & Saatchi advertising network, provides services to Procter &
Gamble and Fromagerie Bel in Syria from its Beirut office.
2. Publicis Groupe has and had no equity participation in Al Cham or any
other legal entity in Syria and so has and had no investment risk. H&C
Leo Burnett received fees from Spacetel totaling $250,000 in 2005 and
$330,000 (estimated) in 2006. Publicis Graphics S.A.R.L. received fees
from Renault totaling $5,000 in each of 2005 and 2006. Saatchi &
Saatchi Beirut SAL received fees from Procter & Gamble and
Fromagerie Bel totaling $285,000 in 2005 and $280,000 in 2006. These
amounts were not material to the financial results of Publicis Groupe
S.A., which had consolidated revenues of approximately EUR 4.1 billion
in 2005.
3. Publicis Groupe S.A. acquired Saatchi & Saatchi in September 2000, and
Bcom3 Group, Inc., parent company of Leo Burnett, in September 2002.
4. Al Cham was erroneously listed on the Publicis Groupe website as an
agency of Publicis in Syria. We have now removed the listing from our
website.
We acknowledge that the company is responsible for the adequacy and accuracy of
the disclosure in its filings with the SEC; that staff comments or changes to
disclosure in response to staff comments do not foreclose the Commission from
taking any action with respect to the filings; and that 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.
Please let the undersigned know if you require any further information.
Sincerely,
Russell Kelley
General Counsel