[REEBOK INTERNATIONAL LTD. LETTERHEAD]
November 8, 2005
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E., Mail Stop 7010
Washington, DC 20549
Pamela A. Long, Assistant Director | ||
| ||
| Re: | Reebok International Ltd. |
|
| Preliminary Proxy Statement on Schedule 14A |
|
| Filed September 21, 2005 |
|
| File No. 001-09340 |
|
| Form 10-K for the year ended December 31, 2004 |
|
| Filed April 15, 2005 |
|
| File No. 001-09340 |
|
| Form 10-Q for the period ended June 30, 2005 |
|
| Filed August 9, 2005 |
|
| File No. 001-09340 |
Dear Ms. Long:
Please be advised that, in connection with the comments issued by the Staff of the Securities and Exchange Commission (the “Commission”) contained in its letter dated October 19, 2005 to Reebok International Ltd. (the “Company”) that pertain to the Company’s Preliminary Proxy Statement on Schedule 14A filed on September 21, 2005 (File No. 001-09340), Form 10-K for the year ended December 31, 2004 filed April 15, 2005 (File No. 001-9340) and Form 10-Q for the period ended June 30, 2005 filed August 9, 2005 (File No. 001-9340) and the Company’s responses thereto, the Company hereby acknowledges that (i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings, (ii) Staff comments or changes to disclosure in response to Staff comments does not foreclose the Commission from taking any actions with respect to the Company’s filings, and (iii) the Company may not assert Staff comments as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very Truly Yours,
/s/ David A. Pace |
David A. Pace
Senior Vice President, General Counsel and Clerk
Reebok International Ltd.