Mail Stop 0407
June 1, 2005
Via U.S. Mail
Mr. Fredrik Rystedt
Chief Financial Officer
Aktiebolaget Electrolux
S:t Goransgatan 143
SE-105 45 Stockholm, Sweden
RE: Aktiebolaget Electrolux (Publ)
Form 20-F for the fiscal year ended December 31, 2004
Filed April 8, 2005
Dear Mr. Rystedt:
We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your documents in response to these comments. If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure. After reviewing this information, we may or may not
raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. 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.
Form 20-F for the fiscal year ended December 31, 2004
Selected Financial Data, page 4
Operating and Financial Review and Prospects, Value Creation, page
30
1. Refer to "Value Creation" and footnote 2. Expand your
disclosures
to discuss the following:
* the specific manner in which you use this non-GAAP measure to
conduct or evaluate the business;
* the economic substance behind your decision to use such a
measure;
* the material limitations associated with the use of this non-
GAAP
measure as compared to the use of the most directly comparable
GAAP
measure, operating income; and
* the manner in which you compensate for these limitations when
using
this non-GAAP measure.
Aggregate Contractual Obligations, page 47
2. Present the required interest payments in the table.
Financial Statements
3. Refer to your asbestos litigations disclosure on page 9.
Please
tell us why the details of the any settlements, accruals and/or
the
range of possible loss related to these litigations are not
required
to be disclosed in the footnotes. Also tell us whether any
settlements and/or accruals considered insurance coverage. If so,
tell us how you accounted for the insurance coverage.
Note 1. Basis of Preparation, page F-8
4. Refer to the last sentence in the first paragraph. Please tell
us
how this accounting policy complies with Swedish GAAP.
Note 3. Segment information, page F-17
5. Refer to your line item "Operating income." Revise the title
here
and all applicable sections of the filing since it is confusingly
similar to operating income under Swedish GAAP.
Note 7. Items affecting comparability (SEK million), page F-20
6. We note that you recorded a provision for loan guarantees in
2003.
Please provide us the details of this provision.
Note 10. Taxes, page F-23
7. Please tell us the nature of the deferred taxes recognized in
equity. Also tell us how this was reflected in the equity
reconciliation in Note 30.
Note 30. Restructuring and other provisions, page F-49
8. Please provide us with a schedule reconciling this provision
with
your provision under Swedish GAAP and tell us the nature of the US
and Swedish GAAP differences.
Note 30. Comprehensive income, page F-55
9. Please refer to footnote 1. We are unable to locate the
description in Item 5. Please advise.
* * * *
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* 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
* 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.
You may contact Michael Henderson, Staff Accountant, at
(202)
551-3364 or Dean Suehiro, Senior Staff Accountant, at (202) 551-
3384
if you have questions regarding comments on the financial
statements
and related matters. Please contact me at (202) 551-3810 with any
other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Fredrik Rystedt
Aktiebolaget Electrolux
June 1, 2005
Page 4
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE