SEC Comment Letter for INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690) (IA) — Apr 12, 2007
INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690)
Date: April 12, 2007 · CIK: 0000836690 · Accession: 0000000000-07-018310
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-140018
Letter
Mail Stop 4561 Geoffrey S. M. Hedrick Chief Executive Officer Innovative Solutions and Support, Inc. 720 Pennsylvania Drive Exton, PA 19341 Form 10-K for September 30, 2006 Filed December 12, 2006 File number 0-31157
RE: Innovative Solutions and Controls, Inc. Amendment No. 1 to Form S-3 Filed Mach 28, 2007 File number 333-140018
Dear Mr. Hedrick:
We have reviewed you above amendment and have the following comments in that regard.
Form S-3 Incorporation of Certain Docu ments by Reference. Page 10 1. Please see our prior comment 5. We note that your definitive proxy soliciting materials were filed on February 5, 2007. According to General Instruction G(3) to Form 10-K, you may incorporate the Part III information only if the definitive proxy soliciting materials are filed within 120 days of the end of your fiscal year. Please amend your Form 10-K to include th e Part III information and then amend your Form S-3 to incorporate that amended Form 10-K by reference.
Geoffrey S. M. Hedrick Innovative Solutions and Support, Inc. April 12, 2007 Page 2 of 2 Please contact Hugh Fuller at (202) 5 51-3853 or me at (202) 551-3730 with any other questions.
S i n c e r e l y ,
Barbara C. Jacobs A s s i s t a n t D i r e c t o r
CC: Stephen M. Leitzell Dechert LLP Cira Centre 2929 Arch Street Philadelphia, PA 19104-2808 Facsimile number: (215) 994-2222
Show Raw Text
April 12, 2007
Mail Stop 4561
Geoffrey S. M. Hedrick
Chief Executive Officer
Innovative Solutions and Support, Inc.
720 Pennsylvania Drive
Exton, PA 19341
RE: Innovative Solutions and Controls, Inc.
Amendment No. 1 to Form S-3
Filed Mach 28, 2007
File number 333-140018
Form 10-K for September 30, 2006
Filed December 12, 2006
File number 0-31157
Dear Mr. Hedrick:
We have reviewed you above amendment and have the following comments in
that regard.
Form S-3
Incorporation of Certain Docu ments by Reference. Page 10
1. Please see our prior comment 5. We note that your definitive proxy soliciting
materials were filed on February 5, 2007. According to General Instruction G(3)
to Form 10-K, you may incorporate the Part III information only if the definitive
proxy soliciting materials are filed within 120 days of the end of your fiscal year.
Please amend your Form 10-K to include th e Part III information and then amend
your Form S-3 to incorporate that amended Form 10-K by reference.
Geoffrey S. M. Hedrick
Innovative Solutions and Support, Inc.
April 12, 2007 Page 2 of 2
Please contact Hugh Fuller at (202) 5 51-3853 or me at (202) 551-3730 with any
other questions.
S i n c e r e l y ,
Barbara C. Jacobs
A s s i s t a n t D i r e c t o r
CC: Stephen M. Leitzell
Dechert LLP
Cira Centre
2929 Arch Street
Philadelphia, PA 19104-2808
Facsimile number: (215) 994-2222