SEC Comment Letter for RadNet, Inc. (RDNT) (CIK 0000790526) (RDNT) — Oct 22, 2008
RadNet, Inc. (RDNT) (CIK 0000790526)
Date: Oct. 22, 2008 · CIK: 0000790526 · Accession: 0000000000-08-052704
AI Filing Summary & Sentiment
File numbers found in text: 001-10593
Referenced dates: September 8, 2008
Letter
Mail Stop 3561 October 22, 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 later dated September 11, 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 comment one of our letter dated September 8, 2008 that you do not currently use performance targets but may establish them in the future. Please confirm that if you do set targ ets you will disclose the specific
Dr. Howard G. Berger RadNet, Inc. October 22, 2008 Page 2 performance targets used or provide a supplemental analysis as to why it is appropriate to omit such disclosure purs uant to Instruction 4 to Item 402 of Regulation S-K.
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
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Mail Stop 3561 October 22, 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 later dated September 11, 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 comment one of our letter dated September 8, 2008 that you do not currently use performance targets but may establish them in the future. Please confirm that if you do set targ ets you will disclose the specific Dr. Howard G. Berger RadNet, Inc. October 22, 2008 Page 2 performance targets used or provide a supplemental analysis as to why it is appropriate to omit such disclosure purs uant to Instruction 4 to Item 402 of Regulation S-K. 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