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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

AI Filing Summary & Sentiment

File numbers found in text: 001-10593

Date
September 8, 2008
Author
John Reynolds
Form
UPLOAD
Company
RadNet, Inc. (RDNT) (CIK 0000790526)

Letter

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

Show Raw Text
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