SEC Comment Letter for MILESTONE SCIENTIFIC INC. (MLSS) (CIK 0000855683) (MLSS) — Jan 7, 2011
MILESTONE SCIENTIFIC INC. (MLSS) (CIK 0000855683)
Date: Jan. 7, 2011 · CIK: 0000855683 · Accession: 0000000000-11-001557
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-14053
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-3030 DIVISION OF CORPORATION FINANCE December 22, 2010 Joseph D’Agostino Chief Financial Officer Milestone Scientific Inc. 220 South Orange Avenue Livingston, NJ 07039 Re: Milestone Scientific Inc. Form 10-K for the Fiscal Year ended December 31, 2009 Filed March 10, 2010 Definitive Proxy Statement filed April 14, 2010 File No. 001-14053
Dear Mr. D’Agostino:
We have reviewed your response letter December 10, 2010 and your subsequent filings and have the following 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 within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances please tell us w hy in your response. After reviewing the information you provide in response to these comments, we may have additional comments.
Joseph D’Agostino Milestone Scientific Inc. December 22, 2010 Page 2 Form 10-K for the Fiscal Year Ended December 31, 2009
Item 12. Security Ownership of Certain Beneficial Owners…, page 29
1. We note your response to prior comment 3. Please tell us with specificity what authority you relied upon for your decision to omit Mr. Martin from the table. With a view towards disclosure, please tell us what Mr. Martin’s holdings were and whether there was other information about Mr. Martin that was not included in your filing, such as disclosure pursuant to Item 404 of Regulati on S-K. Also, please explain in detail the “opposite way transaction subjec t to Section 16(b)” you desc ribe in your response which appears to have occurred after his resignation.
You may contact Kevin Kuhar, Staff Accountant, at (202) 551-3662 or me at (202) 551- 3212 if you have questions regarding comments on th e financial statements and related matters. Please contact Allicia Lam at (202) 551-3316 or Jay Mumford at (202) 551-3637 if you have questions on other comments. In this regard, do not hesitate to contact Martin James, Senior Assistant Chief Accountant, at (202) 551-3157 with any questions.
S i n c e r e l y ,
Jeff Jaramillo A c c o u n t i n g B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3030
DIVISION OF
CORPORATION FINANCE
December 22, 2010
Joseph D’Agostino Chief Financial Officer Milestone Scientific Inc. 220 South Orange Avenue Livingston, NJ 07039
Re: Milestone Scientific Inc.
Form 10-K for the Fiscal Year ended December 31, 2009
Filed March 10, 2010
Definitive Proxy Statement filed April 14, 2010
File No. 001-14053
Dear Mr. D’Agostino:
We have reviewed your response letter December 10, 2010 and your subsequent filings
and have the following 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 within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances please tell us w hy in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Joseph D’Agostino
Milestone Scientific Inc. December 22, 2010 Page 2
Form 10-K for the Fiscal Year Ended December 31, 2009
Item 12. Security Ownership of Certain Beneficial Owners…, page 29
1. We note your response to prior comment 3. Please tell us with specificity what authority
you relied upon for your decision to omit Mr. Martin from the table. With a view
towards disclosure, please tell us what Mr. Martin’s holdings were and whether there was
other information about Mr. Martin that was not included in your filing, such as
disclosure pursuant to Item 404 of Regulati on S-K. Also, please explain in detail the
“opposite way transaction subjec t to Section 16(b)” you desc ribe in your response which
appears to have occurred after his resignation.
You may contact Kevin Kuhar, Staff Accountant, at (202) 551-3662 or me at (202) 551-
3212 if you have questions regarding comments on th e financial statements and related matters.
Please contact Allicia Lam at (202) 551-3316 or Jay Mumford at (202) 551-3637 if you have questions on other comments. In this regard, do not hesitate to contact Martin James, Senior
Assistant Chief Accountant, at (202) 551-3157 with any questions.
S i n c e r e l y ,
Jeff Jaramillo A c c o u n t i n g B r a n c h C h i e f