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SEC Comment Letter for Inotiv, Inc. (NOTV) (CIK 0000720154) (NOTV) — Feb 14, 2013

Inotiv, Inc. (NOTV) (CIK 0000720154)
Date: Feb. 14, 2013 · CIK: 0000720154 · Accession: 0000000000-13-008828

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File numbers found in text: 000-23357

Date
February 12, 2013
Author
/s/ Gus Rodriguez
Form
UPLOAD
Company
Inotiv, Inc. (NOTV) (CIK 0000720154)

Letter

February 1 4, 2013 Via E -mail Ms. Jacqueline Lemke President a nd Chief Executive Officer , Chief Financial Officer and Vice President -Finance Bioanalytical Systems, Inc. 2701 Kent Avenue West Lafayette, IN 47906 -1382

Re: Bioanalytical Systems, Inc. Item 4.01 Form 8 -K Filed February 12, 2013 File No. 000-23357

Dear Ms. Lemke :

We have reviewed your filing and have the following comment s.

Please respond to this letter within five business days by amending your filing or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropria te, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment s.

After reviewing any amendment to your filing and the information you provide in response to our comm ents, we may have additional comments.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exch ange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

Item 4.01 Changes in Registrant’s Certify ing Accountant (a) Dismissal of Previous Independent Registered Public Accounting Firm, page 2

1. Please confirm that you will amend this Item 4.01 8 -K to:  Disclose the effective date of the dismissal of Crowe Horwarth LLP once they have completed their rev iew services for the quarterly period ended March 31, 2013; and  Update the interim period related to paragraphs (a)(1)(iv) and (a)(2) of Item 304 of Regulation S -K through the effective date of dismissal.

Ms. Jacqueline Lemke Bioanalytical Systems, Inc. February 13, 2013 Page 2

2. Upon amending your filing, please include, as Ex hibit 16, an updated letter from your former accountants, Crowe Horwarth, LLP, addressing the revised 8 -K disclosure, as required by Item 304(a)(3) of Regulation S -K.

In responding to our comment s, please provide a written statement from the company ackn owledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;  staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the fili ng; 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, please call Keira Nakada, Staff Accountant, at (202) 551 - 3659.

Sincerely,
/s/ Gus Rodriguez

Show Raw Text
February 1 4, 2013

Via E -mail
Ms. Jacqueline Lemke
President a nd Chief Executive Officer ,
Chief Financial Officer and Vice President -Finance
Bioanalytical Systems, Inc.
2701 Kent Avenue
West Lafayette, IN  47906 -1382

Re: Bioanalytical Systems, Inc.
Item 4.01  Form 8 -K
Filed  February 12, 2013
 File No. 000-23357

Dear Ms. Lemke :

We have reviewed your filing  and have the following comment s.

Please  respond to this letter within five business days by amending your filing or by
advising us when you will provide the requested response.  If  you do not believe our comment
applies  to your facts and circumstances or do not believe an amendment is appropria te, please
tell us why in your response.  Please furnish us a letter on EDGAR under the form type label
CORRESP that keys  your response to our comment s.

After reviewing any amendment to your filing and the information you provide in
response to our comm ents, we may have additional comments.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exch ange Act rules require. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Item 4.01 Changes in Registrant’s Certify ing Accountant
(a) Dismissal of Previous Independent Registered Public Accounting Firm, page 2

1. Please confirm that you will amend this Item 4.01 8 -K to:
 Disclose the effective date of the dismissal of Crowe Horwarth LLP once they have
completed their rev iew services for the quarterly period ended March 31, 2013; and
 Update the interim period related to paragraphs (a)(1)(iv) and (a)(2) of Item 304 of
Regulation S -K through the effective date of dismissal.

Ms. Jacqueline Lemke
Bioanalytical Systems, Inc.
February 13, 2013
 Page 2

 2. Upon amending your filing, please include, as Ex hibit 16, an updated letter from your
former accountants, Crowe Horwarth, LLP, addressing the revised 8 -K disclosure, as
required by Item 304(a)(3) of Regulation S -K.

In responding to our comment s, please provide a written statement from the company
ackn owledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the fili ng; 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, please call Keira Nakada, Staff Accountant,  at (202) 551 -
3659.

       Sincerely,

       /s/ Gus Rodriguez

       Gus Rodiguez
       Accounting Branch Chief