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SEC Company Response from NUTRITION 21 INC (CIK 0000744962) — Apr 11, 2005

NUTRITION 21 INC (CIK 0000744962)
Date: April 11, 2005 · CIK: 0000744962 · Accession: 0001144204-05-010998

AI Filing Summary & Sentiment

File numbers found in text: 333-122880

Date
April 11, 2005
Author
Vice President, General Counsel & Secretary
Form
CORRESP
Company
NUTRITION 21 INC (CIK 0000744962)

Letter

April 11, 2005 By Edgar "CORRESP" Jeffrey P. Riedler Albert Lee Securities and Exchange Commission Washington, DC 20549

Re: Nutrition 21, Inc. (the "Company") S-3/A Filing on April 4, 2005 Registration Statement No. 333-122880

Dear Mr. Riedler and Mr. Lee,

Nutrition 21, Inc. hereby requests acceleration of its above-referenced registration statement on Form S-3/A so that it may become effective at 3:00 PM, April 11, 2005 or as soon thereafter as is practicable. Telephone confirmation of the effectiveness to our counsel, Oscar Folger, at (212) 697-6464, would be greatly appreciated.

The Company acknowledges the following:

1. Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

2. The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

3. The Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,
/s/ Benjamin T. Sporn
--------------------------------------------
By: Benjamin T. Sporn
Vice President, General Counsel & Secretary

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
         Benjamin T. Sporn
         General Counsel
         Nutrition 21, Inc.
         4 Manhattanville Road
         Purchase, NY 10577
         (914) 701-4500

          April 11, 2005

          By Edgar "CORRESP"

          Jeffrey P. Riedler
          Albert Lee
          Securities and Exchange Commission
          Washington, DC 20549

          Re:     Nutrition 21, Inc. (the "Company")
                  S-3/A Filing on April 4, 2005
                  Registration Statement No. 333-122880

          Dear Mr. Riedler and Mr. Lee,

         Nutrition 21, Inc. hereby requests acceleration of its above-referenced
         registration statement on Form S-3/A so that it may become effective at
         3:00 PM, April 11, 2005 or as soon thereafter as is practicable.
         Telephone confirmation of the effectiveness to our counsel, Oscar
         Folger, at (212) 697-6464, would be greatly appreciated.

         The Company acknowledges the following:

            1.    Should the Commission or the staff, acting pursuant to
                  delegated authority, declare the filing effective, it does not
                  foreclose the Commission from taking any action with respect
                  to the filing;

            2.    The action of the Commission or the staff, acting pursuant to
                  delegated authority, in declaring the filing effective, does
                  not relieve the Company from its full responsibility for the
                  adequacy and accuracy of the disclosure in the filing; and

            3.    The Company may not assert this action as a defense in any
                  proceeding initiated by the Commission or any person under the
                  federal securities laws of the United States.

                                   Sincerely,

                                   /s/ Benjamin T. Sporn
                                   --------------------------------------------
                                   By: Benjamin T. Sporn
                                   Vice President, General Counsel & Secretary

         Copy to: Oscar Folger, Esq.

</TEXT>
</DOCUMENT>