[DR. REDDY'S LOGO]
Dr. Reddy's Laboratories Ltd.
7-1-27 Ameerpet
Hyderabad 500 016 India
Tel: 91 40 373 1946
Fax: 91 40 373 1955
www.drreddys.com
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February 10, 2006
Cecilia Byle, Chief
Office of Global Security Risk
Securities and Exchange Commission
Washington, D.C. 20549
United States of America
Re: Dr. Reddy's Laboratories Limited
Form 20-F for fiscal year ended March 31, 2004
Letter from Securities and Exchange Commission dated September
30, 2005 File No. 1-15182
Dear Ms. Byle:
With reference to your letter dated September 30, 2005 requesting supplemental
information in connection with Dr. Reddy's Laboratories Limited's contacts with
countries that have been identified as state sponsors of terrorism, set forth
below are our responses to your letter. For your convenience, your requests for
supplemental information have been restated below in italics.
Form 20-F for fiscal year ended March 31, 2004
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General -
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We note that in your June 20, 2005 response to our December 28, 2004 comment
letter, you state that you do not have any marketing operations for your Active
Pharmaceutical Ingredients (API) segment in North Korea or Syria. Please clarify
whether you have any type of contacts with either North Korea or Syria. You also
responded that your "API segment markets a limited number of products in Iran."
Please describe the products you market in Iran, including their uses. Clarify
whether you have any contacts with Iran other than through your API segment, and
advise us of the dollar total of revenue related to Iran for all company
segments for 2004.
We also note that your 20-F for the fiscal year ended March 31, 2005 states at
page 37 that certain of your Formulations have been certified by Sudan's
Ministry of Health. Please identify all contacts you have with Sudan, the
products you market in Sudan and their uses; and the dollar total of revenue
related to Sudan for all company segments for 2004.
Cecilia Byle, Chief
Office of Global Security Risk
Securities and Exchange Commission
February 10, 2006
Page 2
Please discuss the materiality of your operations or contacts with Iran, Syria
(if any), North Korea (if any), and/or Sudan, and whether those contacts,
individually or in the aggregate, constitute a material investment risk for your
security holders. In preparing your response, please consider that evaluations
of materiality should not be based solely on quantitative factors, but should
include consideration of all factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of
corporate activities upon a company's reputation and share value. In this
regard, we note that Arizona and Louisiana have adopted legislation requiring
divestment from, or reporting of interests in, companies that do business with
U.S.-designated state sponsors of terrorism. We note also that Illinois and New
Jersey have adopted legislation requiring divestment from, or reporting of
interests in, companies that do business with Sudan, and several other U.S.
states recently have proposed similar legislation.
Response: We do not have any material operations in either North Korea or Syria,
nor do we have any type of contacts with either North Korea or Syria.
Our Active Pharmaceutical Ingredients (API) segment markets a limited number of
products in Iran. Our sales in Iran, which are conducted through independent
agents, were as follows for the fiscal year ended March 31, 2004:
Product Quantity (KG) Sales ($US) Therapeutic Category/Sub-category
Ibuprofen 25,000 $203,550 Pain management/Analgesic
Enrofloxacin 6,000 138,000 Anti-infective/Anti-bacterial (used for
veterinary purposes)
Ranitidine 7,000 129,500 Gastro-intestinal/Anti-ulcerant
HCI Form 2
TOTAL $471,050
Our Formulations segment markets a limited number of products in Sudan through
independent distributors. Our sales in Sudan for the fiscal year ended March 31,
2005 were as follows:
Sales Therapy
Product Name Dosage Form Strength (in $US) Category
Cardiopril 10 mg Capsules 10mg $10,000 Cardiovascular
Cardiopril 5 mg Capsules 5mg 5,159 Cardiovascular
Ciprolet 500 mg Tablets 500mg 269,610 Anti Infective
Enam 10 mg Tablets 10mg 13,203 Cardiovascular
Enam 5 mg Tablets 5mg 4,988 Cardiovascular
Lanzap Caps Capsules 30mg 68,340 Gastro Intestinal
Reclide 80 mg Tablets 80mg 5,964 Diabeto
Cecilia Byle, Chief
Office of Global Security Risk
Securities and Exchange Commission
February 10, 2006
Page 3
Sales Therapy
Product Name Dosage Form Strength (in $US) Category
Stamlo 5 mg Tablets 5mg 68,916 Cardiovascular
TOTAL $446,180
We do not view the foregoing sales to Iran or Sudan as material to the revenues
in our API or Formulations segments, nor to our overall revenues. We have no
contacts with Iran other than through our API segment, and have no contacts with
Sudan other than through our Formulations segment.
We do not anticipate that our current or planned operations in Iran or Sudan
will be material to the operations of the Company. We do not believe that our
API marketing activities in Iran or our Formulations marketing activities in
Sudan constitute a material investment risk for our security holders.
We acknowledge that:
o our company is responsible for the adequacy and accuracy of the disclosure
in our SEC filings;
o staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to our SEC
filings; and
o our 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.
Should you have any concerns or questions, please call me at the number listed
above.
Respectfully submitted,
Dr. Reddy's Laboratories Limited
By: /s/ V. Viswanath
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V. Viswanath
Company Secretary