SEC Comment Letter for RadNet, Inc. (RDNT) (CIK 0000790526) (RDNT) — Sep 8, 2008
RadNet, Inc. (RDNT) (CIK 0000790526)
Date: Sept. 8, 2008 · CIK: 0000790526 · Accession: 0000000000-08-045098
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File numbers found in text: 001-10593
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Mail Stop 3561 September 8, 2008 Howard G. Berger, M.D. Principal Executive Officer RadNet, Inc. 1510 Cotner Avenue Los Angeles, California 90025 Re: RadNet, Inc. Form 10-K for Fiscal Year Ended December 31, 2007 Filed February 29, 2008 File No. 001-10593 Dear Dr. Berger: We have reviewed your response late r dated August 12, 2008 and have the following comment. We have asked you to provide us with additional information so we may better understand your disclosure. Pleas e do so within the time frame set forth below. You should comply with the comment in all future filings, as applicable. Please confirm in writing that you will do so and also explain to us how you intend to comply, within the time frame set fort h below. Please understand th at after our review of your response, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment. Feel free to call us at the telephone numbers listed at th e end of this letter. Schedule 14A Compensation of Directors and Executive Officers, page 29 1. We note your response to prior comment one and the statement that you do not currently use performance targets. We note, however, disclosure on page 25 of your proxy statement indicating that you and the CEO intend to review “strategic Dr. Howard G. Berger RadNet, Inc. September 8, 2008 Page 2 objectives and performance targets” and th at you will review the appropriateness of the financial measures used in incen tive plans and the degree of difficulty in achieving specific performance targets. Y ou also state on page 25 that corporate performance objectives “typically are established on the basis of a targeted return on capital” used for the company or a part icular business unit. With a view to disclosure in future filings, please advise us of the “strategic objectives and performance targets” referenced on page 25. It is unclear what those targets relate to and why they are not relevant to prio r comment one. For example, it is unclear if the company considered using performan ce targets but later decided otherwise. Advise us of what disclosure the company intends to provide in future filings regarding these targets. We may have further comment. As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. 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 all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Any questions may be directed to Cath ey Baker at (202) 551-3326 or to James Lopez, who supervised the review of your filing, at (202) 551-3790. Sincerely, John Reynolds Assistant Director cc: Jeffrey Linden, Esq. FAX: (310) 445-2980