SEC Company Response from ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528) (OMEX) — Sep 15, 2011
ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528)
Date: Sept. 15, 2011 · CIK: 0000798528 · Accession: 0001193125-11-248899
AI Filing Summary & Sentiment
File numbers found in text: 001-31895
Letter
VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Corporation Finance Attention: Mr. Justin Dobbie Filed February 28, 2011 Definitive Proxy Statement on Schedule 14A Filed April 15, 2011 SEC File No.: 001-31895
Dear Mr. Dobbie:
The purpose of this letter is to respond to the Staff’s comments during our teleconference on September 13, 2011 with respect to the above-referenced filing. Set forth below are our responses, which are consistent with our discussions.
Annual Incentive Compensation and Targets, page 17
Management Response:
•
Based upon our conversations, we confirm that in future filings we will quantify all performance goals or targets and the goals and targets actually achieved in order for our named executive officers to earn their annual incentive compensation and to quantify all performance goals or targets and the goals and targets actually achieved in order for our named executive officers to earn their annual incentive compensation to include disclosure of the matrix for each performance indicator and the actual achievement of the indicator within the respective matrix.
•
Based upon our conversations, we acknowledge with respect to the last completed fiscal year that the disclosure of the matrix and such information would not have resulted in actual competitive harm to the company.
•
To the extent that facts and circumstances change in the future, we reserve our right to assert that disclosure of such information could result in competitive harm in compliance with rules and regulations of the Securities and Exchange Commission.
Securities and Exchange Commission
September 15, 2011
Page - -
*******
In connection with the Company’s response to the Comment Letter, the Company hereby acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in the filings; and
•
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.
Please feel free to contact me at (813) 314-2565 should you have any questions regarding this response.
Very truly yours,
ODYSSEY MARINE EXPLORATION, INC.
Show Raw Text
CORRESP 1 filename1.htm Correspondence 5215 W. Laurel Street Tampa, FL 33607 Tele: (813)876-1776 Fax: (813) 870-1921 September 15, 2011 VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C.20549 Attention: Mr. Justin Dobbie Re: Odyssey Marine Exploration, Inc. (the “Company”) Form 10-K for the Year Ended December 31, 2010 Filed February 28, 2011 Definitive Proxy Statement on Schedule 14A Filed April 15, 2011 SEC File No.: 001-31895 Dear Mr. Dobbie: The purpose of this letter is to respond to the Staff’s comments during our teleconference on September 13, 2011 with respect to the above-referenced filing. Set forth below are our responses, which are consistent with our discussions. Annual Incentive Compensation and Targets, page 17 Management Response: • Based upon our conversations, we confirm that in future filings we will quantify all performance goals or targets and the goals and targets actually achieved in order for our named executive officers to earn their annual incentive compensation and to quantify all performance goals or targets and the goals and targets actually achieved in order for our named executive officers to earn their annual incentive compensation to include disclosure of the matrix for each performance indicator and the actual achievement of the indicator within the respective matrix. • Based upon our conversations, we acknowledge with respect to the last completed fiscal year that the disclosure of the matrix and such information would not have resulted in actual competitive harm to the company. • To the extent that facts and circumstances change in the future, we reserve our right to assert that disclosure of such information could result in competitive harm in compliance with rules and regulations of the Securities and Exchange Commission. Securities and Exchange Commission September 15, 2011 Page - 2 - ******* In connection with the Company’s response to the Comment Letter, the Company hereby acknowledges that: • the Company is responsible for the adequacy and accuracy of the disclosure in the filings; and • 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. Please feel free to contact me at (813) 314-2565 should you have any questions regarding this response. Very truly yours, ODYSSEY MARINE EXPLORATION, INC. /s/ Michael J. Holmes Michael J. Holmes Chief Financial Officer