Contrarian Corpus
activist regulatory filing
2007-08-02 · 3 pages

Whole Foods Market, Inc. WFMI

N 1 Narrative
V 1 Visual
C 1 Craft
Original source ↗

Primary demands

  • Revise future filings to clarify that disclosure controls also ensure information is accumulated and communicated to management per Exchange Act Rule 13a-15(e)
  • Provide written acknowledgement that the company is responsible for the adequacy and accuracy of its disclosures

Pattern membership

Where this document fits across the library's 12 rhetorical / structural patterns.

Notes

Misfiled in the JANA Partners folder: this is an SEC Division of Corporation Finance staff comment letter from Branch Chief William Choi to Whole Foods CFO Glenda Chamberlain, dated 2007-08-02. It is routine regulatory correspondence about a single Item 9A disclosure-controls wording issue in WFMI's FY2006 10-K — not activist material, not primary JANA content, and contains no thesis, stake, valuation, or campaign argument. Included in the corpus presumably because JANA had a 2007-era position in Whole Foods, but the document itself is SEC-authored.