SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for RadNet, Inc. (RDNT) (CIK 0000790526) (RDNT) — Sep 7, 2010

RadNet, Inc. (RDNT) (CIK 0000790526)
Date: Sept. 7, 2010 · CIK: 0000790526 · Accession: 0000000000-10-051830

AI Filing Summary & Sentiment

File numbers found in text: 333-169107

Date
September 7, 2010
Author
Not clearly detected
Form
UPLOAD
Company
RadNet, Inc. (RDNT) (CIK 0000790526)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-5546 DIVISION OF CORPORATION FINANCE September 7, 2010 Howard G. Berger, M.D. Principal Executive Officer RadNet, Inc. 1510 Cotner Avenue Los Angeles, CA 90025 Re: RadNet, Inc. Registration Statement on Form S-4 Filed August 30, 2010 File No. 333-169107

Dear Mr. Berger: We have limited our review of your registration st atement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropria te, please tell us why in your response. After reviewing any amendment to your regist ration statement and the information you provide in response to these comments, we may have additional comments.

1. Please contact us regarding a request for accelerat ion for the Form S-4 at the completion of the staff’s review of your Form 10-K for the fiscal year ended December 31, 2009.

We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Secu rities Act of 1933 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are re sponsible for the accuracy and adequacy of the disclosures they have made. Notwithstanding our comments, in the event you re quest acceleration of th e effective date of the pending registration statement please prov ide a written statement from the company acknowledging that:

Howard G. Berger, M.D. RadNet, Inc. September 7, 2010 Page 2

• should the Commission or the staff, acting pursua nt to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not re lieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or a ny person under the federal securities laws of the United States. Please refer to Rules 460 and 461 regarding re quests for acceleration. We will consider a written request for acceleration of th e effective date of the registrati on statement as confirmation of the fact that those requesting acceleratio n are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the propos ed public offering of the securities specified in the above registration statement. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

Please contact Susann Reilly at (202) 551-3236 or James Lopez at (202) 551-3536 with any questions. Sincerely, John Reynolds A s s i s t a n t D i r e c t o r Office of Beverages, Apparel and Health Care Services cc: Linda G. Michaelson, Esq. Via facsimile at 310-228-3701

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

                 DIVISION OF
       CORPORATION FINANCE

September 7, 2010
 Howard G. Berger, M.D. Principal Executive Officer RadNet, Inc. 1510 Cotner Avenue Los Angeles, CA 90025
Re: RadNet, Inc.
  Registration Statement on Form S-4
Filed August 30, 2010
  File No. 333-169107

Dear Mr. Berger:
 We have limited our review of your registration st atement to those issues we have addressed in
our comments.  In some of our comments, we may ask you to provide us with information so we may
better understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropria te, please tell us why in your response.
 After reviewing any amendment to your regist ration statement and the information you provide
in response to these comments, we may have additional comments.

1. Please contact us regarding a request for accelerat ion for the Form S-4 at the completion of the
staff’s review of your Form 10-K for the fiscal year ended December 31, 2009.

We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure in the
filing to be certain that the filing includes the information the Secu rities Act of 1933 and all applicable
Securities Act rules require.  Since the company and its management are in possession of all facts
relating to a company’s disclosure, they are re sponsible for the accuracy and adequacy of the
disclosures they have made.
Notwithstanding our comments, in the event you re quest acceleration of th e effective date of
the pending registration statement please prov ide a written statement from the company
acknowledging that:

Howard G. Berger, M.D.
RadNet, Inc.
September 7, 2010
Page 2

• should the Commission or the staff, acting pursua nt to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with respect to the
filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring
the filing effective, does not re lieve the company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and

• the company may not assert staff comments and the declaration of effectiveness as a defense in
any proceeding initiated by the Commission or a ny person under the federal securities laws of
the United States.
 Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of th e effective date of the registrati on statement as confirmation of the
fact that those requesting acceleratio n are aware of their respective responsibilities under the Securities
Act of 1933 and the Securities Exchange Act of 1934 as they relate to the propos ed public offering of
the securities specified in the above registration statement.  Please allow adequate time for us to review
any amendment prior to the requested effective date of the registration statement.

Please contact Susann Reilly at (202) 551-3236 or James Lopez at (202) 551-3536 with any
questions.
Sincerely,     John Reynolds
       A s s i s t a n t  D i r e c t o r
Office of Beverages, Apparel and  Health Care Services
cc:  Linda G. Michaelson, Esq. Via facsimile at 310-228-3701