-----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, ClwQpjsInrFcrQCIAB1z/gNngEpRfQo7O7uDFVyy0jjtFYLx2qx9dFDNW20iQ2u8 lvIN1m7iEEOszRYsIT+VbQ== 0000000000-06-062456.txt : 20070514 0000000000-06-062456.hdr.sgml : 20070514 20061221153201 ACCESSION NUMBER: 0000000000-06-062456 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20061221 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: CISCO SYSTEMS INC CENTRAL INDEX KEY: 0000858877 STANDARD INDUSTRIAL CLASSIFICATION: COMPUTER COMMUNICATIONS EQUIPMENT [3576] IRS NUMBER: 770059951 STATE OF INCORPORATION: CA FISCAL YEAR END: 0728 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 170 WEST TASMAN DR CITY: SAN JOSE STATE: CA ZIP: 95134-1706 BUSINESS PHONE: 4085264000 MAIL ADDRESS: STREET 1: 225 WEST TASMAN DR CITY: SAN JOSE STATE: CA ZIP: 95134-1706 LETTER 1 filename1.txt Mail Stop 4561 December 21, 2006 Dennis D. Powell Senior Vice President and Chief Financial Officer Cisco Systems, Inc. 170 West Tasman Drive San Jose, CA 95134-1706 Re: Cisco Systems, Inc. Form 10-K for the Fiscal Year Ended July 29, 2006 Filed September 18, 2006 File No. 000-18225 Dear Mr. Powell: We have the following additional comments regarding your Form 10-K. 1. We note from your company website and a public report that you may have operations in Syria, a country identified as a state sponsor of terrorism by the State Department and subject to export controls and sanctions administered by the Commerce Department`s Bureau of Industry and Security and the Treasury Department`s Office of Foreign Assets Control. Your Form 10-K discloses that you have operations in the Middle East but does not contain information relating specifically to operations in or contacts with Syria. Please describe your current, past and anticipated operations in and contacts with Syria, if any, including through subsidiaries, affiliates and other direct and indirect arrangements. 2. Discuss the materiality to you of the operations and contacts described in your response to the foregoing comment, in light of Syria`s status as a state sponsor of terrorism. Please also discuss whether the operations or contacts constitute a material investment risk to your security holders. Please describe the extent to which the government of Syria or entities controlled by it are intermediaries or receive financing in connection with your operations associated with that country. 3. Your materiality analysis should address materiality in quantitative terms, including the approximate dollar amount of revenues, assets and liabilities associated with Syria. Please address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon your reputation and share value. For example, we note that Arizona and Louisiana have adopted legislation requiring their state retirement systems to prepare reports regarding state pension fund assets invested in, and/or permitting divestment of state pension fund assets from, companies that do business with countries identified as state sponsors of terrorism. The Missouri Investment Trust has established an equity fund for the investment of certain state-held monies that screens out stocks of companies that do business with U.S.-designated state sponsors of terrorism. We note also that the Pennsylvania legislature has adopted a resolution directing its Legislative Budget and Finance Committee to report annually to the General Assembly regarding state funds invested in companies that have ties to terrorist-sponsoring countries. Your materiality analysis should address the potential impact of the investor sentiment evidenced by such actions directed toward companies operating in Syria. Please also address the impact of your regulatory compliance programs, such as programs designed to prevent terrorism funding, which cover operations and contacts associated with Syria, and any internal risk assessment undertaken in connection with business in Syria. * * * * * You may contact me at (202) 551-3730 if you have questions regarding these comments. Sincerely, Barbara C. Jacobs Assistant Director Dennis D. Powell Cisco Systems, Inc. December 21, 2006 Page 1 -----END PRIVACY-ENHANCED MESSAGE-----