[LETTERHEAD OF CBS CORPORATION]
April 23, 2014
Mr. Larry Spirgel
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, DC 20549
Phone: 202-551-3810
|
|
Form 10-K for Fiscal Year Ended December 31, 2013
|
|
|
Filed February 14, 2014
|
|
|
File No. 001-09553
|
Dear Mr. Spirgel:
On behalf of CBS Corporation (“CBS” or the “Company”), and in connection with the letter dated April 23, 2014 and addressed to your attention from Stephen T. Giove of Shearman & Sterling LLP, which sets forth our responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received in your letter dated April 9, 2014 concerning the Company’s Form 10-K for the fiscal year ended December 31, 2013, the Company hereby acknowledges that:
|
|
·
|
the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
|
|
|
·
|
Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing; and
|
| Page 2 | April 23, 2014 |
|
|
·
|
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.
|
* * *
If you have any questions concerning the matters referred to in this letter, please call Stephen T. Giove at Shearman & Sterling LLP at (212) 848-7325.
|
Sincerely,
|
||
|
/s/ Joseph R. Ianniello
|
||
|
Joseph R. Ianniello
|
||
|
Chief Operating Officer
|
|
cc:
|
Leslie Moonves, President and Chief Executive Officer
Gary L. Countryman, Chair of the Audit Committee
Lawrence Tu, Senior Executive Vice President and Chief Legal Officer
Lawrence Liding, Senior Vice President, Controller and Chief Accounting Officer
Scott Feinstein, PricewaterhouseCoopers LLP
Kathryn Jacobson, Securities and Exchange Commission
Robert S. Littlepage, Securities and Exchange Commission
Emily Drazan, Securities and Exchange Commission
|