October 11, 1996
Mr. Mark S. Brinton
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Dear Mr. Brinton:
RE: Thiokol Corporation
Form S-3 Registration Statement
File No. 333-1753
We are responding herein to the comments contained in the Staff's letter
dated October 8, 1996 (the "Comment Letter") to Amendment No. 2 to the
Registration Statement on Form S-3 (the "Registration Statement") of
Thiokol Corporation (the "Company") filed on September 26, 1996 and the
Company's Form 10-K for the fiscal year ended June 30, 1996 and subsequent
1934 Act reports filed by the Company with the Securities and Exchange
Commission (the "Commission") and incorporated by reference into the
Registration Statement. Each of the numbered responses below corresponds to
the Staff's numbered comments. Capitalized terms used herein and not
otherwise defined have the meanings assigned to them in the Registration
Statement.
1. If material, please disclose in future filings the accounting
treatment for the joint ventures with Alliant Technologies, Inc. and Morton
International, Inc.
Company Response: In response to the Staff's comment, the Company will
include such disclosure in future filings if material.
2. In future filings, please clarify that revenue is recognized under
the percentage of completion method, if this is the case. The term
"generally" when referring to the accounting treatment should be deleted.
<PAGE>
Mark S. Brinton
Form S-3 Registration Statement
File No. 333-1753
Page 2
Company Response: In response to the Staff's comment, the Company will in
future filings clarify that revenue is recognized under the percentage of
completion method, if applicable, and will delete the term "generally" when
referring to the accounting treatment.
The Company also hereby requests acceleration pursuant to Rule 461 under
the Securities Act of 1933, as amended, of its Registration Statement on
Form S-3 (Registration No. 333-1753) so that such registration statement
will be declared effective at 1:00 p.m. Washington, D.C. time on Wednesday,
October 16, 1996, or as soon as practicable thereafter.
If you have any questions, please contact Tad Freese of Latham & Watkins at
(415) 395-8184 or the undersigned at (801) 629-2084.
Sincerely,
\s\Edwin M. North
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Corporate Secretary
EMN:dlw
