View:
September
19, 2007
Mellissa
Campbell Duru, Attorney Advisor
United
States Securities and Exchange Commission
Washington,
DC 20549
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Re: The
Hershey
Company
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Definitive Proxy Statement on Schedule
14A
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Filed: March 16,
2007
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File No. 000-00183
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Dear
Ms.
Duru:
This
letter confirms our telephone conversation of September 14,
2007. During that conversation, you agreed to extend, until October
31, 2007, the deadline for The Hershey Company (the “Company,” “we” or “our”) to
respond to the August 21, 2007 comment letter (“Comment Letter”) from the
Division of Corporation Finance, Securities and Exchange Commission (“SEC”)
regarding executive compensation and other related disclosure in our 2007
Proxy
Statement on Schedule 14A.
As
I
explained to you during the telephone conversation, we intend to solicit
the
input of members of the Compensation and Executive Organization Committee
(“Committee”) of our Board of Directors in developing our formal response to the
Comment Letter. The Committee will provide this input as part of its
regularly scheduled meeting in early October. Following that meeting,
we will finalize our response and circulate a final draft to the Committee
for
approval. Once final approval is received, we will forward the
response to the SEC. This process will be completed at the earliest
possible date, but in any event no later than October 31, 2007.
Thank
you
for providing us with sufficient additional time to prepare our response
to the
Comment Letter.
Sincerely,
/s/
Steven J. Holsinger
Steven
J.
Holsinger
Vice
President,
Governance
and
Compliance