SEC Company Response from RadNet, Inc. (RDNT) (CIK 0000790526) (RDNT) — Jan 3, 2008
RadNet, Inc. (RDNT) (CIK 0000790526)
Date: Jan. 3, 2008 · CIK: 0000790526 · Accession: 0001019687-08-000041
AI Filing Summary & Sentiment
File numbers found in text: 001-33307
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(COMPANY LETTERHEAD)
January 3, 2008
VIA EDGAR AND FEDEX
Ms. Susann Reilly
U.S. Securities and Exchange Commission Mail Stop 3561 100 F. Street, N.E.
Washington, D.C. 20549
Re: RadNet, Inc. - Form 10-K/T for the Transition Period from
November 1, 2006 to December 31, 2006 filed on April 17, 2007
(File No. 001-33307)
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Dear Ms. Reilly:
We are responding to the comments in your letter to RadNet, Inc., dated
December 28, 2007, concerning our Form 10-K/T referred to above.
Set forth below are our responses to the Staff's comments. For your
convenience, we have included each of the Comments in italicized text before the
corresponding response.
RESPONSES:
CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, PAGE 71
1. IN FUTURE FILINGS, FOR TRANSACTIONS WITH RELATED PERSONS, PLEASE
COMPLY WITH THE DISCLOSURE REQUIREMENTS OF ITEM 404(A) OF REGULATION
S-K. FOR EXAMPLE, IN REGARDS TO THE RELATED TRANSACTION BETWEEN RADNET
AND BRMG, PLEASE INCLUDE THE APPROXIMATE DOLLAR VALUE OF THE AMOUNT
INVOLVED IN THE TRANSACTION AND THE APPROXIMATE DOLLAR VALUE OF THE
AMOUNT OF THE RELATED PERSON'S INTEREST IN THE TRANSACTION. SEE ITEM
404(A)(3) AND (4) OF REGULATION S-K.
We respectfully submit to you that, in future filings, we will comply
with the disclosure requirements of Item 404(a) of Regulation S-K.
2. IN FUTURE FILINGS, PLEASE DISCLOSE WHETHER YOUR POLICIES AND
PROCEDURES FOR REVIEW, APPROVAL, OR RATIFICATION OF RELATED PERSON
TRANSACTIONS ARE IN WRITING AND, IF NOT, EXPLAIN HOW YOU EVIDENCE YOUR
POLICIES AND PROCEDURES. SEE ITEM 404(B)(1)(IV) OF REGULATION S-K.
We respectfully submit to you that, in future filings, we will
disclose whether our policies and procedures for review, approval, or
ratification of related person transactions are in writing and, if
not, we will explain how we evidence our policies and procedures.
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Ms. Susann Reilly
January 3, 2008
Page 2
In connection with this response, we hereby acknowledge that:
o the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
o staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to
the filing; and
o the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
If you have any questions, please contact me at (310) 445-2840.
Very truly yours,
/s/ Howard G. Berger, M.D.
Howard G. Berger, M.D.
Chief Executive Officer
cc: David Swartz, Audit Committee Chairman, RadNet, Inc.
Jeffrey Linden, Executive Vice President and General Counsel
Linda Michaelson, Esq.
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