Mr John Hartz Corus
Senior Assistant Chief Accountant 30 Millbank
United States London SW1P 4WY
Securities and Exchange Commission United Kingdom
100 F Street, NE Direct Tel +44(0) 20 7717 4444
Washington, D.C. 20549-7010 Direct Fax +44(0) 20 7717 4556
Direct Fax +44(0) 20 7717 4643
5 December 2005
RE: Corus Group plc
Form 20-F for the fiscal year ended January 1, 2005
Filed March 31, 2005
File No. 1-10120
Dear Mr Hartz
I refer to your letter of November 21, 2005. We welcome your continued
contribution to assist us in complying with all applicable disclosure
requirements and to enhance the overall disclosure of our filing.
We have reviewed your further comments and we have indicated below the approach
we will adopt in future filings to address these.
Form 20-F for the fiscal year ended January 1, 2005
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Accounting Policies, pages 50-51
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1. We have reviewed your response to comment 2 in our letter dated October 5,
2005. We note that your risk factor, titled "Certain business decisions
concerning Corus' business require approval by the Corus Nederland Supervisory
Board, a body whose composition is not wholly within the control of Corus",
casts some doubt about your ability to control and, therefore, consolidate,
Corus Nederland. In future filings, please expand your discussion under this
risk factor or within your critical accounting policies to address how you
determined that notwithstanding the rights of the Supervisory Board, you still
have the ability to control Corus Nederland. In this regard, specifically
address the fact that the Supervisory Board has no authority to establish or
make operating and capital decisions, including the setting or approval of
Corus Group plc
Registered in England No. 3811373
Registered Office 30 Millbank
London SW1P 4WY
Page 2 of 2
budgets, or powers to incur or reject the incurrence of additional indebtedness
(unless these proposals include significant acquisitions and disposals).
1. We confirm that, in future filings, we will expand our discussion under this
risk factor to address how we determined that we have the ability to control
Corus Nederland, picking up the specific factors to which you refer.
* * * *
We trust that the above response is clear and provides you with the necessary
information, but please feel free to contact me for further details.
Yours sincerely
David Lloyd
Executive Director, Finance
Corus Group plc