SEC Comment Letter for ATRION CORP (CIK 0000701288) — Mar 27, 2020
ATRION CORP (CIK 0000701288)
Date: March 27, 2020 · CIK: 0000701288 · Accession: 0000000000-20-002684
AI Filing Summary & Sentiment
File numbers found in text: 001-32982
Letter
March 27, 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, 2019 Filed March 2, 2020 Response dated March 4, 2020 File No. 001-32982 Dear Mr. Strickland: We have reviewed your March 4, 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 February 19, 2020 letter. Response dated March 4, 2020 Item 1. Business Patents and License Agreements, page 3 1.We note your response to our prior comment that you have not disclosed the name of the product for which patent protection will expire in August 2022 for competitive reasons. Please note that we deem this information to be material to investors. Accordingly, please confirm that you will disclose the name of the product in future filings. As other material product related patents approach expiration, please confirm that you will disclose the pending expiration and the associated product. Please contact Ada D. Sarmento at 202-551-3798 or Suzanne Hayes at 202-551-3675 with any questions.
FirstName LastNameJeffery Strickland Comapany NameAtrion Corporation March 27, 2020 Page 2 FirstName LastName Jeffery Strickland Atrion Corporation March 27, 2020 Page 2 Sincerely, Division of Corporation Finance Office of Life Sciences cc: B. G. Minisman, Jr., Esq.
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March 27, 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, 2019
Filed March 2, 2020
Response dated March 4, 2020
File No. 001-32982
Dear Mr. Strickland:
We have reviewed your March 4, 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
February 19, 2020 letter.
Response dated March 4, 2020
Item 1. Business
Patents and License Agreements, page 3
1.We note your response to our prior comment that you have not disclosed the name of the
product for which patent protection will expire in August 2022 for competitive reasons.
Please note that we deem this information to be material to investors. Accordingly, please
confirm that you will disclose the name of the product in future filings. As other material
product related patents approach expiration, please confirm that you will disclose the
pending expiration and the associated product.
Please contact Ada D. Sarmento at 202-551-3798 or Suzanne Hayes at 202-551-3675
with any questions.
FirstName LastNameJeffery Strickland
Comapany NameAtrion Corporation
March 27, 2020 Page 2
FirstName LastName
Jeffery Strickland
Atrion Corporation
March 27, 2020
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: B. G. Minisman, Jr., Esq.