UPLOAD: SEC-generated letter
Published on July 13, 2006
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546
DIVISION OF
CORPORATION FINANCE
Mail Stop 5546
July 7, 2006
Via Facsimile (404) 515-2546 and US Mail
E. Neville Isdell
Chief Executive Officer
The Coca Cola Company
One Coca-Cola Plaza
Atlanta, Georgia 30313
Re: The Coca Cola Company
Form 10-K for the Fiscal Year Ended December 31, 2005
Filed February 28, 2006
Response Letter Dated May 26, 2006
File No. 1-2217
Dear Mr. Isdell:
We have reviewed your response letter dated May 26, 2006 and
have the following comment. Please be as detailed as necessary in
your response. We welcome any questions you may have about our
comments or on any other aspect of our review. Feel free to call
us
at the telephone numbers listed at the end of this letter.
General
1. You state in your response to prior comment two that you
provide
concentrates to bottlers in Iran and Sudan pursuant to an OFAC
license that is renewed annually, and you have secured an export
license to provide certain information and know-how to Cadbury
Schweppes bottlers in Syria. You also state that two bottlers,
including one in which you have a minority interest, have sold
your
products into Syria since 2004; that you intend to grant
distribution
rights for your finished products with respect to Syria to a new
distribution company which will source your products from bottlers
in
the region; and that you have a minority ownership interest in one
of
the bottlers expected to participate in the new distribution
company.
You do not discuss OFAC or BIS licensing in connection with any of
these bottling or distribution arrangements. Please explain
whether
you have received licenses for these arrangements, or rely on
general
licenses, or the arrangements are exempt from OFAC and BIS
licensing
requirements.
Please file your response letter on EDGAR. Please contact
James Lopez at (202) 551-3536 if you have any questions about the
comments or our review. You may also contact me at (202) 551-
3470.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Christopher Owings
Assistant Director
Division of Corporation Finance
Mr. E. Neville Isdell
The Coca Cola Company
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