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SEC Company Response from PSYCHIATRIC SOLUTIONS INC (CIK 0000829608) — Nov 8, 2005

PSYCHIATRIC SOLUTIONS INC (CIK 0000829608)
Date: Nov. 8, 2005 · CIK: 0000829608 · Accession: 0000950144-05-011380

AI Filing Summary & Sentiment

Referenced dates: November 7, 2005

Date
November 8, 2005
Author
/s/ Christopher L. Howard
Form
CORRESP
Company
PSYCHIATRIC SOLUTIONS INC (CIK 0000829608)

Letter

VIA EDGAR Securities and Exchange Commission Attention: Division of Corporate Finance Psychiatric Solutions, Inc. Schedule 14A Filed November 3, 2005 File Number 0-20488

Dear Mr. Riedler:

On behalf of Psychiatric Solutions, Inc. (the “Company”), attached as Schedule I is the Company’s response to the comment included in the staff’s letter, dated November 7, 2005, regarding the above-referenced Schedule 14A. The response in Schedule I is keyed to the staff’s comment, which is repeated and underlined in Schedule I for convenience of reference.

In connection with responding to the Commission’s comments, the Company acknowledges the following:

•

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

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

•

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.

Please contact the undersigned at (615) 312-5851 or James H. Nixon III at (615) 850-8855 if you have any questions regarding the Company’s response.

Very truly yours,
/s/ Christopher L. Howard

Show Raw Text
CORRESP
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corresp

[PSI LETTERHEAD]

November 8, 2005

VIA EDGAR

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

    Attention:

    Jeffrey P. Riedler

    Division of Corporate Finance

                   Re:

    Psychiatric Solutions, Inc.

    Schedule 14A

    Filed November 3, 2005

    File Number 0-20488

Dear Mr. Riedler:

     On behalf of Psychiatric Solutions, Inc. (the “Company”), attached as Schedule
I is the Company’s response to the comment included in the staff’s letter, dated November 7,
2005, regarding the above-referenced Schedule 14A. The response in Schedule I is keyed to
the staff’s comment, which is repeated and underlined in Schedule I for convenience of
reference.

     In connection with responding to the Commission’s comments, the Company acknowledges the
following:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
filing;

    •

    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

    •

    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.

     Please contact the undersigned at (615) 312-5851 or James H. Nixon III at (615) 850-8855 if
you have any questions regarding the Company’s response.

Very truly yours,

/s/ Christopher L. Howard

    cc:

    Greg Belliston

    Joey A. Jacobs

    Brent Turner

    James H. Nixon III

    John J. Faldetta, Jr.

SCHEDULE I

Psychiatric Solutions, Inc.

Schedule 14A

File No. 0-20488

Comment 1: Please discuss the reasons for the stock split.

Response 1: The first paragraph of the section of the Company’s Preliminary Proxy Statement
entitled “Purposes of the Proposed Amendment” shall be amended and restated in the Definitive Proxy
Statement to address the Commission’s comment as follows:

     “Purposes of the Proposed Stock Split and Amendment

     On November 1, 2005, the Board of Directors conditionally approved a
two-for-one stock split to be effected in the form of a stock dividend of one share
of Common Stock for each share of Common Stock outstanding on December 27, 2005, the
proposed record date for the stock split. The stock split is conditioned upon
approval by the stockholders of the Amendment. The Board of Directors believes that
the stock split is in the best interest of the Company and its stockholders because
it is expected to place the market price of the Company’s common stock in a range
that is more attractive to investors and may result in improved market liquidity and
enhanced trading volume for the Company’s shares. The primary purpose of the
Amendment is to provide a sufficient number of shares of Common Stock to effect the
stock split, pursuant to which each stockholder of record on December 27, 2005 would
be entitled to receive on January 9, 2006 one additional share of Common Stock for
each share of Common Stock held.”