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
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File numbers found in text: 333-169107
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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