SEC Comment Letter for DERMA SCIENCES, INC. (CIK 0000892160) — Apr 14, 2005
DERMA SCIENCES, INC. (CIK 0000892160)
Date: April 14, 2005 · CIK: 0000892160 · Accession: 0000000000-05-018192
AI Filing Summary & Sentiment
File numbers found in text: 333-123940
Letter
Mail Stop 0309 April 14, 2005 Edward J. Quilty President Derma Sciences, Inc. 214 Carnegie Center, Suite 100 Princeton, NJ 08540
Re: Derma Sciences, Inc. Registration Statement on Form S-3 File Number 333-123940
Dear Mr. Quilty:
This is to advise you that we are not conducting a full review of the above registration statement. However, we will be reviewing the accounting disclosure in your Form 10-KSB for the period ended December 31, 2004. You will receive our accounting comments under separate cover. All comments will need to be fully resolved before we take final action on the registration statement.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event the company requests acceleration of the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:
* should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
* the company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing.
We will consider a written request for acceleration of the effective date of the registration statement as a confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. We will act on the request and, pursuant to delegated authority, grant acceleration of the effective date.
Please contact Greg Belliston at (202) 824-5219 or me at (202) 942-1840 with any questions.
Sincerely,
Jeffrey P. Riedler
Assistant Director
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> Mail Stop 0309 April 14, 2005 Edward J. Quilty President Derma Sciences, Inc. 214 Carnegie Center, Suite 100 Princeton, NJ 08540 Re: Derma Sciences, Inc. Registration Statement on Form S-3 File Number 333-123940 Dear Mr. Quilty: This is to advise you that we are not conducting a full review of the above registration statement. However, we will be reviewing the accounting disclosure in your Form 10-KSB for the period ended December 31, 2004. You will receive our accounting comments under separate cover. All comments will need to be fully resolved before we take final action on the registration statement. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Notwithstanding our comments, in the event the company requests acceleration of the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that: * should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; * the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and * the company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing. We will consider a written request for acceleration of the effective date of the registration statement as a confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. We will act on the request and, pursuant to delegated authority, grant acceleration of the effective date. Please contact Greg Belliston at (202) 824-5219 or me at (202) 942-1840 with any questions. Sincerely, Jeffrey P. Riedler Assistant Director cc: Raymond C. Hedger, Jr., Esq. Hedger & Hedger 2 Fox Chase Drive P.O. Box 915 Hershey, PA 17033 ?? ?? ?? ?? Edward J. Quilty Derma Sciences, Inc. April 14, 2005 Page 1 </TEXT> </DOCUMENT>