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Division of Corporation Finance
2019 No-Action Letters Issued Under Exchange Act Rule 14a-8
Important Note: This page contains no-action letters the Division of Corporation Finance issued under Exchange Act Rule 14a-8 during calendar year 2019. Where we take written action on correspondence following the date of a no-action letter, you may find the later materials in the link presented below the citation to the original no-action letter. Pursuant to the Federal Information Security Management Act of 2002 and OMB Memorandum M-07-16, we have removed, to the maximum extent practicable, personally identifiable information from the materials.
Additional Archives
2019-2020 | Jan.-Nov. 2019 | 2018 | 2017 | 2016 | 2015 | 2014 | 2013 | 2012 | 2011 | 2010 | 2009 | 2008 | 2007
Alphabetical Listing
A
- Abbott Laboratories, February 28, 2019
- Abbott Laboratories, February 28, 2019
- AbbVie Inc., February 28, 2019
- AbbVie Inc., February 27, 2019
- AbbVie Inc., February 15, 2019
- AbbVie Inc., January 30, 2019
- Advance Auto Parts, Inc., April 9, 2019
- The AES Corporation, February 21, 2019
- Air Products and Chemicals, Inc., October 15, 2019
- The Allstate Corporation,, March 15, 2019
- Alphabet Inc., April 19, 2019
- Alphabet Inc., April 16, 2019
- Amazon.com, Inc., April 3, 2019
- Amazon.com, Inc., April 3, 2019
- Amazon.com, Inc., April 3, 2019
- Amazon.com, Inc., March 28, 2019
- Amazon.com, Inc., March 28, 2019
- Amazon.com, Inc., March 28, 2019
- Amazon.com, Inc., March 6, 2019
- Amazon.com, Inc., March 4, 2019
- AMC Networks Inc., April 23, 2019
- American Outdoor Brands Corporation, June 25, 2019
- Ameriprise Financial, Inc., February 14, 2019
- Anadarko Petroleum Corporation, March 4, 2019
- Annaly Capital Management, Inc., February 22, 2019
- Anthem, Inc., February 21, 2019
- Anthem, Inc., February 15, 2019
- AT&T Inc., January 29, 2019
- AT&T Inc., January 29, 2019
- AutoZone, Inc., October 9, 2019
Top of list
B
- Bank of America Corporation, February 26, 2019
- Bank of America Corporation, February 21, 2019
- Bank of America Corporation, February 21, 2019
- Bank of America Corporation, February 15, 2019
- The Bank of New York Mellon Corporation, February 15, 2019
- BlackRock, Inc., March 21, 2019
- Bristol-Myers Squibb Company, March 8, 2019
- Bristol-Myers Squibb Company, March 1, 2019
Top of list
C
- Cadence Design Systems, Inc., February 27, 2019
- Caterpillar Inc., April 4, 2019
- CBRE Group, Inc., March 18, 2019
- CBRE Group, Inc., March 6, 2019
- CBS Corporation, March 15, 2019
- CBS Corporation, March 8, 2019
- CBS Corporation, February 1, 2019
- Cheniere Energy, Inc., February 25, 2019
- Chevron Corporation, March 28, 2019
- Chevron Corporation, March 15, 2019
- Citigroup Inc., January 28, 2019
- The Clorox Company, August 7, 2019
- The Coca-Cola Company, February 21, 2019
- Comcast Corporation, April 4, 2019
- Comcast Corporation, March 14, 2019
- CoreCivic, Inc., March 15, 2019
- CoreCivic, Inc., March 15, 2019
- CorVel Corporation, June 5, 2019
- Costco Wholesale Corporation, October 16, 2019
- Costco Wholesale Corporation, October 2, 2019
Top of list
D
- Devon Energy Corporation, March 4, 2019
- Domino's Pizza, Inc., February 19, 2019
- Dover Corporation, February 6, 2019
- Duke Energy Corporation, March 12, 2019
- Duke Energy Corporation, March 6, 2019
- Dunkin' Brands Group, Inc., March 6, 2019
Top of list
E
- eBay Inc., April 10, 2019
- Eli Lilly and Company, February 28, 2019
- Eli Lilly and Company, March 1, 2019
- Eli Lilly and Company, February 22, 2019
- Exelon Corporation, March 12, 2019
- Exxon Mobil Corporation, April 3, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, March 29, 2019
- Exxon Mobil Corporation, March 28, 2019
- Exxon Mobil Corporation, March 28, 2019
- Exxon Mobil Corporation, March 25, 2019
Top of list
F
- FedEx Corporation, June 5, 2019
- Ferro Corporation, February 6, 2019
- FleetCor Technologies, Inc., April 4, 2019
- Fitbit, Inc., March 20, 2019
- Fortive Corporation, March 13, 2019
- Frontier Communications Corporation, February 19, 2019
Top of list
G
- General Dynamics Corporation, February 11, 2019
- General Electric Company, March 6, 2019
- General Electric Company, March 5, 2019
- General Electric Company, March 1, 2019
- General Electric Company, February 15, 2019
- The GEO Group, Inc., March 15, 2019
- The GEO Group, Inc., March 15, 2019
- Gilead Sciences, Inc., March 7, 2019
- Gilead Sciences, Inc., March 6, 2019
- The Goldman Sachs Group, Inc., March 12, 2019
- The Goldman Sachs Group, Inc., February 5, 2019
Top of list
H
- Hanesbrands Inc., February 5, 2019
- HCA Healthcare, Inc., February 21, 2019
- Hecla Mining Company, March 1, 2019
- Hess Corporation, April 11, 2019
- HollyFrontier Corporation, February 11, 2019
- Honeywell International Inc., March 1, 2019
Top of list
I
Top of list
J
- J.B. Hunt Transport Services, Inc., February 14, 2019
- Johnson & Johnson, February 28, 2019
- Johnson & Johnson, February 14, 2019
- Johnson & Johnson, February 6, 2019
- Johnson & Johnson, February 8, 2019
- Johnson & Johnson, February 11, 2019
- JPMorgan Chase & Co., March 15, 2019
- JPMorgan Chase & Co., March 15, 2019
- JPMorgan Chase & Co., March 15, 2019
- JPMorgan Chase & Co., March 22, 2019
- JPMorgan Chase & Co., March 20, 2019
- JPMorgan Chase & Co., March 20, 2019
- JPMorgan Chase & Co., March 19, 2019
- JPMorgan Chase & Co., March 13, 2019
- JPMorgan Chase & Co., February 21, 2019
Top of list
K
Top of list
L
Top of list
M
- Marathon Petroleum Corporation, March 8, 2019
- Marathon Oil Corporation, February 21, 2019
- Martin Marietta Materials, Inc., March 1, 2019
- MasterCard Incorporated, April 25, 2019
- Mastercard Incorporated, April 24, 2019
- McDonald's Corporation, March 22, 2019
- McDonald's Corporation, March 12, 2019
- McDonald's Corporation, March 7, 2019
- McDonald's Corporation, March 5, 2019
- McDonald's Corporation, March 5, 2019
- MetLife, Inc., March 18, 2019
- MGE Energy, Inc., March 13, 2019
- MGE Energy, Inc., February 6, 2019
- Microsoft Corporation, August 6, 2019
- Mondeléz International, Inc., February 21, 2019
- Mondeléz International, Inc., February 21, 2019
- Mylan N.V., April 30, 2019
Top of list
N
- NCR Corporation, February 15, 2019
- Nektar Therapeutics, March 28, 2019
- New York Comminity Bancorp, Inc., April 11, 2019
- NextEra Energy, Inc., March 19, 2019
- NIKE, Inc., June 25, 2019
- NIKE, Inc., June 5, 2019
- Northrop Grumman Corporation, March 19, 2019
- Norfolk Southern Corporation, February 6, 2019
- Northrop Grumman Corporation, March 13, 2019
- NTN Buzztime, Inc., April 11, 2019
Top of list
O
Top of list
P
- PACCAR Inc., January 28, 2019
- Pacific Gas and Electric Company, January 30, 2019
- Paycom Software, Inc., February 1, 2019
- PDL BioPharma, Inc., March 1, 2019
- PepsiCo, Inc., March 8, 2019
- PepsiCo, Inc., February 22, 2019
- PepsiCo, Inc., February 14, 2019
- PepsiCo, Inc., January 28, 2019
- Pfizer Inc., February 28, 2019
- Pfizer Inc., February 28, 2019
- Pfizer Inc., March 1, 2019
- Pfizer Inc., February 28, 2019
- Pfizer Inc., February 12, 2019
- Pfizer Inc., February 7, 2019
- PG&E Corporation, March 13, 2019
- Philip Morris International Inc., January 31, 2019
- Phillips 66, March 13, 2019
- Pinnacle West Capital Corporation, February 1, 2019
- PNM Resources, Inc., April 2, 2019
- PNM Resources, Inc., April 2, 2019
- PNM Resources, Inc., March 22, 2019
- PPG Industries, Inc., February 8, 2019
- The Procter & Gamble Company, July 15, 2019
Top of list
R
Top of list
S
- Saga Communications, Inc., March 12, 2019
- SBA Communications Corporation, February 6, 2019
- Sempra Energy, January 31, 2019
- Senior Housing Properties Trust, March 13, 2019
- The Southern Company, March 13, 2019
- SunTrust Banks, Inc., February 5, 2019
- Sturm, Ruger & Company, Inc., February 28, 2019
- Sturm, Ruger & Company, Inc., February 28, 2019
- Symantec Corporation, August 5, 2019
Top of list
T
- Texas Instruments Incorporated, February 28, 2019
- TheStreet, Inc., March 8, 2019
- The TJX Companies, Inc., April 9, 2019
- Tractor Supply Company, March 12, 2019
- TransDigm Group Incorporated, January 28, 2019
- Trans World Entertainment Corporation, May 2, 2019
- Trans World Entertainment Corporation, May 2, 2019
Top of list
U
Top of list
V
- Valero Energy Corporation, January 31, 2019
- Valero Energy Corporation, January 28, 2019
- Verizon Communications Inc., February 19, 2019
- Verizon Communications Inc., February 15, 2019
- Verizon Communications Inc., February 14, 2019
- Verizon Communications Inc., February 14, 2019
- Verizon Communications Inc., January 30, 2019
- Verizon Communications Inc., January 29, 2019
- Visa Inc., October 11, 2019
- Visa Inc., October 30, 2019
Top of list
W
- Walmart Inc., April 8, 2019
- Walmart Inc., March 28, 2019
- Wells Fargo & Company, March 5, 2019
- Wells Fargo & Company, February 27, 2019
- Wells Fargo & Company, March 1, 2019
- Wells Fargo & Company, February 27, 2019
- Wells Fargo & Company, February 21, 2019
- The Wendy's Company, April 10, 2019
Top of list
XYZ
- XPO Logistics, Inc., April 4, 2019
- XPO Logistics, Inc., April 4, 2019
- XPO Logistics, Inc., March 6, 2019
- Yum! Brands, Inc., March 6, 2019
Top of list
Chronological Listing
October
- Visa Inc., October 30, 2019
- Costco Wholesale Corporation, October 16, 2019
- AutoZone, Inc., October 9, 2019
- Air Products and Chemicals, Inc., October 15, 2019
- Visa Inc., October 11, 2019
- Costco Wholesale Corporation, October 2, 2019
Top of list
August
Top of list
July
Top of list
June
- American Outdoor Brands Corporation, June 25, 2019
- NIKE, Inc., June 25, 2019
- CorVel Corporation, June 5, 2019
- FedEx Corporation, June 5, 2019
- NIKE, Inc., June 5, 2019
Top of list
May
Top of list
April
- Mylan N.V., April 30, 2019
- MasterCard Incorporated, April 25, 2019
- Mastercard Incorporated, April 24, 2019
- AMC Networks Inc., April 23, 2019
- Alphabet Inc., April 19, 2019
- Hess Corporation, April 11, 2019
- Alphabet Inc., April 16, 2019
- New York Comminity Bancorp, Inc., April 11, 2019
- NTN Buzztime, Inc., April 11, 2019
- eBay Inc., April 10, 2019
- Rite Aid Corporation, April 10, 2019
- The Wendy's Company, April 10, 2019
- Advance Auto Parts, Inc., April 9, 2019
- The TJX Companies, Inc., April 9, 2019
- Caterpillar Inc., April 4, 2019
- Comcast Corporation, April 4, 2019
- FleetCor Technologies, Inc., April 4, 2019
- United Therapeutics Corporation, April 4, 2019
- XPO Logistics, Inc., April 4, 2019
- XPO Logistics, Inc., April 4, 2019
- Walmart Inc., April 8, 2019
- Amazon.com, Inc., April 3, 2019
- Amazon.com, Inc., April 3, 2019
- Amazon.com, Inc., April 3, 2019
- Exxon Mobil Corporation, April 3, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- Exxon Mobil Corporation, April 2, 2019
- PNM Resources, Inc., April 2, 2019
- PNM Resources, Inc., April 2, 2019
- Reliance Steel & Aluminum Co., April 2, 2019
Top of list
March
- Exxon Mobil Corporation, March 29, 2019
- Ross Stores, Inc., March 29, 2019
- Amazon.com, Inc., March 28, 2019
- Chevron Corporation, March 28, 2019
- Exxon Mobil Corporation, March 28, 2019
- Walmart Inc., March 28, 2019
- Amazon.com, Inc., March 28, 2019
- Amazon.com, Inc., March 28, 2019
- Exxon Mobil Corporation, March 28, 2019
- Nektar Therapeutics, March 28, 2019
- Exxon Mobil Corporation, March 25, 2019
- KeyCorp, March 22, 2019
- JPMorgan Chase & Co., March 22, 2019
- McDonald's Corporation, March 22, 2019
- PNM Resources, Inc., March 22, 2019
- BlackRock, Inc., March 21, 2019
- Fitbit, Inc., March 20, 2019
- JPMorgan Chase & Co., March 20, 2019
- JPMorgan Chase & Co., March 20, 2019
- JPMorgan Chase & Co., March 19, 2019
- NextEra Energy, Inc., March 19, 2019
- Northrop Grumman Corporation, March 19, 2019
- CBRE Group, Inc., March 18, 2019
- JPMorgan Chase & Co., March 15, 2019
- JPMorgan Chase & Co., March 15, 2019
- JPMorgan Chase & Co., March 15, 2019
- Intel Corporation, March 15, 2019
- MetLife, Inc., March 18, 2019
- The Allstate Corporation,, March 15, 2019
- CBS Corporation, March 15, 2019
- Chevron Corporation, March 15, 2019
- CoreCivic, Inc., March 15, 2019
- CoreCivic, Inc., March 15, 2019
- The GEO Group, Inc., March 15, 2019
- The GEO Group, Inc., March 15, 2019
- Comcast Corporation, March 14, 2019
- Royal Caribbean Cruises Ltd., March 14, 2019
- Fortive Corporation, March 13, 2019
- JPMorgan Chase & Co., March 13, 2019
- MGE Energy, Inc., March 13, 2019
- Northrop Grumman Corporation, March 13, 2019
- PG&E Corporation, March 13, 2019
- Phillips 66, March 13, 2019
- Senior Housing Properties Trust, March 13, 2019
- The Southern Company, March 13, 2019
- The Goldman Sachs Group, Inc., March 12, 2019
- Duke Energy Corporation, March 12, 2019
- Exelon Corporation, March 12, 2019
- Tractor Supply Company, March 12, 2019
- McDonald's Corporation, March 12, 2019
- Saga Communications, Inc., March 12, 2019
- Invesco Ltd., March 8, 2019
- PepsiCo, Inc., March 8, 2019
- Bristol-Myers Squibb Company, March 8, 2019
- CBS Corporation, March 8, 2019
- Marathon Petroleum Corporation, March 8, 2019
- TheStreet, Inc., March 8, 2019
- United Technologies Corporation, March 8, 2019
- Gilead Sciences, Inc., March 7, 2019
- McDonald's Corporation, March 7, 2019
- Amazon.com, Inc., March 6, 2019
- CBRE Group, Inc., March 6, 2019
- Dunkin' Brands Group, Inc., March 6, 2019
- Duke Energy Corporation, March 6, 2019
- General Electric Company, March 6, 2019
- Gilead Sciences, Inc., March 6, 2019
- XPO Logistics, Inc., March 6, 2019
- Yum! Brands, Inc., March 6, 2019
- Wells Fargo & Company, March 5, 2019
- McDonald's Corporation, March 5, 2019
- General Electric Company, March 5, 2019
- McDonald's Corporation, March 5, 2019
- Amazon.com, Inc., March 4, 2019
- Anadarko Petroleum Corporation, March 4, 2019
- Devon Energy Corporation, March 4, 2019
- PDL BioPharma, Inc., March 1, 2019
- United Technologies Corporation, March 1, 2019
- Wells Fargo & Company, March 1, 2019
- Martin Marietta Materials, Inc., March 1, 2019
- Pfizer Inc., March 1, 2019
- Bristol-Myers Squibb Company, March 1, 2019
- Eli Lilly and Company, March 1, 2019
- General Electric Company, March 1, 2019
- Hecla Mining Company, March 1, 2019
- Honeywell International Inc., March 1, 2019
Top of list
February
- Eli Lilly and Company, February 28, 2019
- Abbott Laboratories, February 28, 2019
- AbbVie Inc., February 28, 2019
- Johnson & Johnson, February 28, 2019
- Pfizer Inc., February 28, 2019
- Abbott Laboratories, February 28, 2019
- Pfizer Inc., February 28, 2019
- Pfizer Inc., February 28, 2019
- Sturm, Ruger & Company, Inc., February 28, 2019
- Sturm, Ruger & Company, Inc., February 28, 2019
- Texas Instruments Incorporated, February 28, 2019
- AbbVie Inc., February 27, 2019
- Wells Fargo & Company, February 27, 2019
- Cadence Design Systems, Inc., February 27, 2019
- Wells Fargo & Company, February 27, 2019
- Bank of America Corporation, February 26, 2019
- Cheniere Energy, Inc., February 25, 2019
- Annaly Capital Management, Inc., February 22, 2019
- Eli Lilly and Company, February 22, 2019
- Leidos Holdings, Inc., February 22, 2019
- PepsiCo, Inc., February 22, 2019
- Anthem, Inc., February 21, 2019
- Bank of America Corporation, February 21, 2019
- Bank of America Corporation, February 21, 2019
- JPMorgan Chase & Co., February 21, 2019
- Marathon Oil Corporation, February 21, 2019
- Mondeléz International, Inc., February 21, 2019
- Mondeléz International, Inc., February 21, 2019
- The Coca-Cola Company, February 21, 2019
- Wells Fargo & Company, February 21, 2019
- HCA Healthcare, Inc., February 21, 2019
- The AES Corporation, February 21, 2019
- Domino's Pizza, Inc., February 19, 2019
- Frontier Communications Corporation, February 19, 2019
- Bank of America Corporation, February 15, 2019
- Anthem, Inc., February 15, 2019
- General Electric Company, February 15, 2019
- Verizon Communications Inc., February 19, 2019
- NCR Corporation, February 15, 2019
- The Bank of New York Mellon Corporation, February 15, 2019
- AbbVie Inc., February 15, 2019
- Kaman Corporation, February 15, 2019
- Verizon Communications Inc., February 15, 2019
- Johnson & Johnson, February 14, 2019
- Ameriprise Financial, Inc., February 14, 2019
- Verizon Communications Inc., February 14, 2019
- Verizon Communications Inc., February 14, 2019
- J.B. Hunt Transport Services, Inc., February 14, 2019
- PepsiCo, Inc., February 14, 2019
- Pfizer Inc., February 12, 2019
- General Dynamics Corporation, February 11, 2019
- HollyFrontier Corporation, February 11, 2019
- Johnson & Johnson, February 11, 2019
- Johnson & Johnson, February 8, 2019
- PPG Industries, Inc., February 8, 2019
- Pfizer Inc., February 7, 2019
- Johnson & Johnson, February 6, 2019
- Dover Corporation, February 6, 2019
- Ferro Corporation, February 6, 2019
- MGE Energy, Inc., February 6, 2019
- Norfolk Southern Corporation, February 6, 2019
- SBA Communications Corporation, February 6, 2019
- O'Reilly Automotive, Inc., February 5, 2019
- Hanesbrands Inc., February 5, 2019
- SunTrust Banks, Inc., February 5, 2019
- The Goldman Sachs Group, Inc., February 5, 2019
- Paycom Software, Inc., February 1, 2019
- Pinnacle West Capital Corporation, February 1, 2019
- CBS Corporation, February 1, 2019
Top of list
January
- Kellogg Company, January 31, 2019
- Sempra Energy, January 31, 2019
- Valero Energy Corporation, January 31, 2019
- AbbVie Inc., January 30, 2019
- Pacific Gas and Electric Company, January 30, 2019
- Philip Morris International Inc., January 31, 2019
- Verizon Communications Inc., January 30, 2019
- AT&T Inc., January 29, 2019
- AT&T Inc., January 29, 2019
- Verizon Communications Inc., January 29, 2019
- Citigroup Inc., January 28, 2019
- PACCAR Inc., January 28, 2019
- PepsiCo, Inc., January 28, 2019
- Valero Energy Corporation, January 28, 2019
- TransDigm Group Incorporated, January 28, 2019
Top of list
http://www.sec.gov/divisions/corpfin/cf-noaction/2019_14a-8.shtml
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