January 13, 2006
Mr. Jay Webb
Reviewing Accountant
Mail Stop 6010
U.S. Securities and
Exchange Commission
701 First Street, N.E.
Washington, D.C. 20549
RE: | Edwards Lifesciences Corporation |
| Form 10-K for fiscal year ended December 31, 2004 |
| Filed March 7, 2005 |
| File No. 1-15525 |
| Form 8-K filed October 25, 2005 |
Dear Mr. Webb:
Set forth below are the comments from the Staff’s letter dated January 11, 2006 with respect to Edwards Lifesciences Corporation (the “Company”) Form 10-K as filed with the SEC on March 7, 2005, and Form 8-K as filed on October 25, 2005, and the Company’s responses to those comments.
Form 10-K for the year-end December 31, 2004
Notes to Financial Statements, page 53
Note 2 Summary of Significant Accounting Policies, page 53
Investment in Unconsolidated Affiliates, page 57
STAFF COMMENT
1. We refer to your response to Comment 1 in our letter dated December 8, 2005. Please revise future filings to clearly explain how you evaluated whether or not your investment in Sangamo was permanently impaired at each quarterly and annual balance sheet date and to disclose why management believed no permanent impairment existed until the third quarter of 2005. The requested additional future disclosures should include the significant information outlined in your response to our prior comment.
Edwards Lifesciences Corporation
One Edwards Way Irvine, CA USA 92614
Phone: 949.250.2500 Fax: 949.250.2525 www.edwards.com
U.S. Securities and Exchange Commission
January 13, 2006
COMPANY RESPONSE
We acknowledge the Staff’s comment and will revise future filings.
* * *
If you have any questions regarding the foregoing, please contact the undersigned at (949) 250-6865.
| Sincerely, |
|
|
| /s/ Thomas M. Abate |
| Thomas M. Abate |
| Corporate Vice President, |
| Chief Financial Officer and Treasurer |
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