SEC Comment Letter for ATRION CORP (CIK 0000701288) — Jan 28, 2020
ATRION CORP (CIK 0000701288)
Date: Jan. 28, 2020 · CIK: 0000701288 · Accession: 0000000000-20-000748
AI Filing Summary & Sentiment
File numbers found in text: 001-32982
Letter
January 28, 2020 Jeffery Strickland Chief Financial Officer Atrion Corporation One Allentown Parkway Allen, TX 75002 Re:Atrion Corporation Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 26, 2019 File No. 001-32982 Dear Mr. Strickland: We have reviewed your January 14, 2020 response to our comment letter and have the following comment. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 30, 2019 letter. Response dated January 14, 2020 Item 1. Business Patents and License Agreements, page 3 1.We note your statement in response to comment one indicating that no single patent or license is material to your business as a whole. Please provide a detailed analysis supporting this determination. Your analysis should address how many products you sell and whether any material product or related products are dependent on a patent, series of patents or licence. You may contact Michael Fay at 202-551-3812 or Kristin Lochhead at 202-551-3664 if you have questions regarding comments on the financial statements and related matters. Please contact Ada D. Sarmento at 202-551-3798 or Suzanne Hayes at 202-551-3675 with any other questions.
FirstName LastNameJeffery Strickland Comapany NameAtrion Corporation January 28, 2020 Page 2 FirstName LastName Jeffery Strickland Atrion Corporation January 28, 2020 Page 2 Sincerely, Division of Corporation Finance Office of Life Sciences cc: B. G. Minisman, Jr., Esq.
Show Raw Text
January 28, 2020
Jeffery Strickland
Chief Financial Officer
Atrion Corporation
One Allentown Parkway
Allen, TX 75002
Re:Atrion Corporation
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 26, 2019
File No. 001-32982
Dear Mr. Strickland:
We have reviewed your January 14, 2020 response to our comment letter and have the
following comment.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 30, 2019 letter.
Response dated January 14, 2020
Item 1. Business
Patents and License Agreements, page 3
1.We note your statement in response to comment one indicating that no single patent or
license is material to your business as a whole. Please provide a detailed analysis
supporting this determination. Your analysis should address how many products you sell
and whether any material product or related products are dependent on a patent, series of
patents or licence.
You may contact Michael Fay at 202-551-3812 or Kristin Lochhead at 202-551-3664 if
you have questions regarding comments on the financial statements and related matters. Please
contact Ada D. Sarmento at 202-551-3798 or Suzanne Hayes at 202-551-3675 with any other
questions.
FirstName LastNameJeffery Strickland
Comapany NameAtrion Corporation
January 28, 2020 Page 2
FirstName LastName
Jeffery Strickland
Atrion Corporation
January 28, 2020
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: B. G. Minisman, Jr., Esq.