SEC Company Response from KOPIN CORP (KOPN) (CIK 0000771266) (KOPN) — Jan 13, 2011
KOPIN CORP (KOPN) (CIK 0000771266)
Date: Jan. 13, 2011 · CIK: 0000771266 · Accession: 0001193125-11-007561
AI Filing Summary & Sentiment
File numbers found in text: 000-19882
Referenced dates: December 22, 2010
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CORRESP 1 filename1.htm Response Letter January 13, 2011 VIA EDGAR AND FEDERAL EXPRESS Russell Mancuso Division of Corporation Finance Branch Chief Securities & Exchange Commission 100 F Street N.E. Washington, D.C. 20549 Re: Kopin Corporation Definitive Proxy Statement on Schedule 14A Filed March 17, 2010 File No. 000-19882 Dear Mr. Mancuso, This letter is in response to comments received in the letter dated December 22, 2010 (the “Letter”) from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to John C.C. Fan, President and Chief Executive Officer and Chairman of the Board of Directors of Kopin Corporation (the “Company”), and a follow-up conversation with the Staff on January 11, 2011, regarding incorrect information contained the Company’s Named Executive Officer Summary Compensation Table in its 2010 Definitive Proxy Statement on Schedule 14A filed on March 17, 2010 (the “Proxy Statement”). In response to the Staff’s verbal comments on January 11, 2011, we note that while the Company does not believe an amendment of its 2009 Annual Report on Form 10-K is required to be filed to reflect the inaccuracies in its Proxy Statement, the Company does confirm that disclosure of the corrected compensation amounts on a Form 8-K filing is appropriate. As such the Company shall file contemporaneously with this letter a Form 8-K setting forth the corrected Named Executive Officer Summary Compensation Table. The Company hereby acknowledges the following: • the Company is responsible for the adequacy and accuracy of the disclosure in the filings; • Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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. We would appreciate the opportunity to discuss any remaining questions or concerns with you at your convenience. If you have any further questions, please contact the undersigned at 508.824.6696. Very truly yours, /s/ Richard A. Sneider Richard A. Sneider Chief Financial Officer Cc: Aslynn Hogue, U.S. Securities and Exchange Commission John, J. Concannon, Bingham McCutchen LLP