SEC Comment Letter for KOPIN CORP (KOPN) (CIK 0000771266) (KOPN) — Dec 9, 2010
KOPIN CORP (KOPN) (CIK 0000771266)
Date: Dec. 9, 2010 · CIK: 0000771266 · Accession: 0000000000-10-073882
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19882
Letter
December 9, 2010 Via Facsimile and U.S. Mail John C.C. Fan President, Chief Executive Officer and Chairman of the Board of Directors Kopin Corporation 200 John Hancock Road Taunton, MA 02780 Re: Kopin Corporation Definitive Proxy Statement on Schedule 14A Filed March 17, 2010 File No. 000-19882
Dear Mr. Fan:
We have limited our review of your filing to the issue we have addressed in our comment.
1. In an October 4, 2010 article, The Boston Globe reported that you disclosed incorrect executive compensation amounts in your recent proxy statement. We have reviewed the compensation amounts you reported in your pr oxy statement, and it appears that the amounts are incorrect.
Please contact us no later than 10 days from the date of this letter to tell us what actions you plan to take to correct your executive compensation disc losure or, if you do not plan to correct it, your reasons for reaching your conclu sion that it is not appropriate to do so.
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 Exchange Act rules requir e. 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. In responding to our comment, please provide a written statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
Mr. John C.C. Fan Kopin Corporation December 9, 2010 Page 2
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States. You may contact Aslynn Hogue at (202) 551-3841 or me at (202) 551-3617 with any questions.
S i n c e r e l y ,
R u s s e l l M a n c u s o B r a n c h C h i e f
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December 9, 2010
Via Facsimile and U.S. Mail
John C.C. Fan
President, Chief Executive Officer and Chairman of the Board of Directors Kopin Corporation 200 John Hancock Road Taunton, MA 02780
Re: Kopin Corporation
Definitive Proxy Statement on Schedule 14A
Filed March 17, 2010 File No. 000-19882
Dear Mr. Fan:
We have limited our review of your filing to the issue we have addressed in our
comment.
1. In an October 4, 2010 article, The Boston Globe
reported that you disclosed incorrect
executive compensation amounts in your recent proxy statement. We have reviewed the
compensation amounts you reported in your pr oxy statement, and it appears that the
amounts are incorrect.
Please contact us no later than 10 days from the date of this letter to tell us what actions
you plan to take to correct your executive compensation disc losure or, if you do not plan
to correct it, your reasons for reaching your conclu sion that it is not appropriate to do so.
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 Exchange Act rules requir e. 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.
In responding to our comment, please provide a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
Mr. John C.C. Fan Kopin Corporation December 9, 2010 Page 2
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States.
You may contact Aslynn Hogue at (202) 551-3841 or me at (202) 551-3617 with any
questions.
S i n c e r e l y ,
R u s s e l l M a n c u s o B r a n c h C h i e f