-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, RpYpcR/lsStPjl3NaOyzENeEZw3fnbFRJUv5xE+k6LuQgtLmbD57frE2Him4N9rf fpw2/2Q0AQrhrw3jRB0gNQ== 0000950123-10-093350.txt : 20101129 0000950123-10-093350.hdr.sgml : 20101129 20101015062144 ACCESSION NUMBER: 0000950123-10-093350 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20101015 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SK TELECOM CO LTD CENTRAL INDEX KEY: 0001015650 STANDARD INDUSTRIAL CLASSIFICATION: RADIO TELEPHONE COMMUNICATIONS [4812] IRS NUMBER: 999999999 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11, EULJIRO2-GA STREET 2: JUNG-GU CITY: SEOUL KOREA STATE: M5 ZIP: 100-999 BUSINESS PHONE: 82-2-6100-1639 MAIL ADDRESS: STREET 1: 11, EULJIRO2-GA STREET 2: JUNG-GU CITY: SEOUL STATE: M5 ZIP: 100-999 FORMER COMPANY: FORMER CONFORMED NAME: KOREA MOBILE TELECOMMUNICATIONS CORP DATE OF NAME CHANGE: 19960530 CORRESP 1 filename1.htm corresp
SK Telecom Co., Ltd.
SK T-Tower
11, Eulgiro 2-Ga, Jung-gu, Seoul, Korea
October 15, 2010
VIA EDGAR AND OVERNIGHT DELIVERY
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention:    Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
Re:    SK Telecom Co., Ltd.
Annual Report on Form 20-F for Fiscal Year Ended December 31, 2009
Dear Mr. Spirgel:
     On behalf of SK Telecom Co., Ltd., a corporation organized under the laws of the Republic of Korea (the “Company,” “us” or “we”), this letter responds to the comment letter, dated October 1, 2010, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2009, which was filed with the Commission on June 30, 2010 (the “2009 Annual Report”), which comment letter was addressed to Sang yun Lee, Manager, Investor Relations Department, of the Company (the “Comment Letter”). For your convenience, the Staff’s comment is reproduced below in bold type and italics and is followed by the Company’s response.
Item 7.A. Major Shareholders, page 75
1.     We note your response to comment 4 in our letter dated September 1, 2010. Please refer to General Instruction F to Form 20-F which defines “host country” as the United States and its territories. Please indicate the portion of each class of securities held in the United States and its territories and the number of record holders.
According to Citibank, N.A., depositary for our American Depositary Receipts, as of December 31, 2009, there were 304 U.S. holders of record of our American Depositary Receipts evidencing American Depositary Shares (“ADSs”), and 24,000,794 shares of our common stock were held in the form of ADSs. As of such date, outstanding ADSs represented approximately 33.2% of our outstanding common stock.

 

 

In future filings, we will similarly include the number of record holders of our ADSs and the portion of our outstanding common stock such ADSs represent.
* * *
     This letter constitutes an acknowledgement on behalf of the Company that:
  •   the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
 
  •   Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; 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.
     We would like to thank you for your review of the 2009 Annual Report. We hope that the foregoing is responsive to your inquiries. Please direct any further questions or comments to the Company’s Investor Relations Department, to the attention of Sang yun Lee at 82-2-6100- 1621.
         
  Sincerely,
 		  
  /S/ Dong-Hyun Jang    
  Dong-Hyun Jang   
  Chief Financial Officer   
 
cc:    Jonathan Groff
Staff Attorney
Division of Corporation Finance
 
    Michael Helsel, Esq.
Shareholder
Greenberg Traurig, LLP

 

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