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SEC Company Response from NATURES SUNSHINE PRODUCTS INC (NATR) (CIK 0000275053) (NATR) — Oct 5, 2010

NATURES SUNSHINE PRODUCTS INC (NATR) (CIK 0000275053)
Date: Oct. 5, 2010 · CIK: 0000275053 · Accession: 0001104659-10-051206

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File numbers found in text: 001-34483

Date
December 31, 2009
Author
/s/
Form
CORRESP
Company
NATURES SUNSHINE PRODUCTS INC (NATR) (CIK 0000275053)

Letter

VIA EDGAR & EXPRESS MAIL Securities and Exchange Commission Division of Corporation Finance Attention: Jim B. Rosenberg, Senior Assistant Chief Accountant Re: Nature’s Sunshine Products, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Form 10-q for the Quarterly Periods Ended March 31 and June 30, File No. 001-34483

Dear Mr. Rosenberg:

On behalf of Nature’s Sunshine Products, Inc. (the “Company”), we submit this letter in response to the comments from the Staff of the Securities and Exchange Commission (the “Commission”) to the Company, dated September 22, 2010 (the “Comment Letter”), with respect to the Company’s filings referenced above. In the Comment Letter, the Staff requested the Company to respond within 10 business days, i.e., by October 6, 2010. Based on our prior conversation with the Staff, we hereby request an additional 10 business days to respond to the Comment Letter, i.e., by October 20, 2010. The extension is requested primarily because of the additional time required for the Company’s independent registered public accounting firm, Deloitte & Touche, LLP, to complete its review of the response letter and the proposed amendment to the Form 10-K.

* * *

In connection with the Company’s response to the Comment Letter, 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 do not foreclose the Commission from taking any action with respect to the filings; and

· 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 or comments as to the foregoing, please contact the undersigned.

Sincerely,
/s/
Thomas Kellerman

Show Raw Text
CORRESP
1
filename1.htm

Thomas W. Kellerman

650-843-7550

tkellerman@morganlewis.com

October 5,
2010

VIA
EDGAR & EXPRESS MAIL

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention:   Jim B. Rosenberg, Senior Assistant Chief
Accountant

Tabatha Atkins, Staff Accountant

Re:                             Nature’s
Sunshine Products, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2009

Form 10-q for the Quarterly Periods Ended March 31 and June 30,
2010

File No. 001-34483

Dear
Mr. Rosenberg:

On
behalf of Nature’s Sunshine Products, Inc. (the “Company”), we submit this
letter in response to the comments from the Staff of the Securities and
Exchange Commission (the “Commission”) to the Company, dated September 22,
2010 (the “Comment Letter”), with respect to the Company’s filings referenced
above.  In the Comment Letter, the Staff
requested the Company to respond within 10 business days, i.e., by October 6,
2010.  Based on our prior conversation
with the Staff, we hereby request an additional 10 business days to respond to
the Comment Letter, i.e., by October 20, 2010.  The extension is requested primarily because
of the additional time required for the Company’s independent registered public
accounting firm, Deloitte & Touche, LLP, to complete its review of the
response letter and the proposed amendment to the Form 10-K.

*    *    *

In
connection with the Company’s response to the Comment Letter, 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 do not foreclose the Commission from
taking any action with respect to the filings; and

·                                          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 or comments as to the foregoing, please contact the undersigned.

  Sincerely,

  /s/
  Thomas Kellerman

  Thomas
  Kellerman

  cc:
  Jamon Jarvis