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Published on January 15, 2009
January 15,
2009
Mr. John
Hartz
Senior
Assistant Chief Accountant
Division
of Corporation Finance
United
States Securities and Exchange Commission
Washington,
DC 20549-7010
Re: Your
letter dated January 8, 2009, regarding Ball Corporation’s
Form 10-K
for the Fiscal Year Ended December 31, 2007
Filed
February 25, 2008
File No.
001-7349
Dear Mr.
Hartz:
We
understand that the purpose of your review process is to assist us in complying
with the applicable disclosure requirements and enhancing the overall
disclosures in the filings we make with the Commission and, therefore, we
welcome your input. For your convenience, we have reproduced your
comments below in italics immediately prior to our response.
Form 10-K for Fiscal Year
Ended December 31, 2007
Note 1. Critical
Accounting Policies, page 41
Goodwill and Other
Intangible Assets, page 41
Comment
#1 – We appreciate your
response to our prior comment concerning your critical accounting policies
regarding goodwill and other intangibles. We also note your overall
trading value compared to your book value per share. In future
filings, if a material impairment charge becomes reasonably possible, (for
example, if the fair value of a particular reporting unit is particularly close
to recorded value) you should provide more detailed information about your
assumptions and their sensitivity to change. Since critical
accounting estimates and assumptions can be based on matters that are highly
uncertain companies should analyze their specific sensitivity to change, based
on other outcomes that are reasonably likely to occur and could have a material
impact. If you would like more detailed information about this
disclosure requirement, please see Section 501.14 of the Financial Reporting
Codification.
Thank you
for your consideration of our original responses to you dated December 18,
2008. Regarding the disclosure of an impairment charge of goodwill or
other intangible asset, if we deem such a material charge to be reasonably
possible for any of our reporting units in a future filing period, we will
provide more detailed information regarding our assumptions and their
sensitivity to change in accordance with the guidance in Section 501.14 of the
Financial Reporting Codification.
January 15, 2009
Page 2
We
appreciate your additional comment and believe we have adequately addressed it
in our response.
Sincerely,
/s/ Raymond J.
Seabrook
Raymond
J. Seabrook
Executive
Vice President and Chief Financial Officer