CONFIDENTIAL
April 21, 2005
VIA EDGAR
Mr. Rufus Decker
Accounting Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0510
| RE: | FOIA Confidential Treatment Request |
Stepan Company Form 10-K for the fiscal year ended December 31, 2004
File No. 1-4462
Dear Mr. Decker:
The following are responses to questions submitted telephonically by Scott Watkinson of the SEC in follow-up to Stepan Company’s written response of April 1, 2005 to the SEC comment letter dated March 18, 2005. Confidential follow-up responses are referenced to the comment numbers in the March 18, 2005 comment letter.
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations:
4. Environmental and Legal Matters, Page 26
Follow-up Question: Could the Company confidentially provide the disaggregated environmental site reserves to facilitate the SEC’s understanding of the Company’s response on April 1?
Response: *
| * | Confidential treatment requested by Stepan Company. The confidential portion has been so omitted and filed separately with the SEC. |
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| Securities and Exchange Commission | CONFIDENTIAL |
April 21, 2005
6. Summary of Significant Accounting Policies
Follow-up Question: What are the smaller and more meaningful components of machinery and equipment in dollar terms?
Response:
| Machinery and Equipment |
$ | 621,131 | |
| Computer Software and Equipment |
30,440 | ||
| Other (primarily furniture and vehicles) |
14,650 | ||
| Total Machinery and Equipment |
$ | 666,221 | |
The Company would prefer to continue to present one line item disclosure for all Machinery and Equipment due to the relative small amounts for the additional categories.
If you have any questions or require assistance, please feel free to contact me at (847) 501-2164.
Very truly yours,
James E. Hurlbutt
Vice President - Finance
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