SEC Company Response from AROTECH CORP (CIK 0000916529) — Aug 16, 2005
AROTECH CORP (CIK 0000916529)
Date: Aug. 16, 2005 · CIK: 0000916529 · Accession: 0001144204-05-025736
AI Filing Summary & Sentiment
File numbers found in text: 333-124961
Referenced dates: August 2, 2005
Letter
VIA EDGAR Securities and Exchange Commission Attention: File No. 333-124961 Draft of Amendment to Form 10-K for Fiscal Year Ended December 31, 2004 File No. 0-23336
Dear Ms Fisher:
This letter sets forth the responses of Arotech Corporation (“we” or the “Company”) to the comments contained in the letter (the “Comment Letter”) of the staff of the Securities and Exchange Commission (the “Staff”) dated August 2, 2005 and addressed to Leland Nall, with respect to the filing by the Company of the above-referenced registration statement (the “S-3”) on May 16, 2005.
We filed Amendment No. 1 to the S-3, in response to the Staff’s comments contained in its comment letter of June 8, 2005, on July 20, 2005. We are hereby filing Amendment No. 2 to our Form S-3. We have executed manually executed signature pages and consents prior to the time of the electronic filing. For the Staff’s convenience, we are enclosing six courtesy copies of Amendment No. 2 to the S-3; three copies are clean, and three copies have been marked to show changes from the S-3. We are also enclosing three copies of this letter, containing the Company’s responses to the Comment Letter.
Concurrent with our filing of Amendment No. 2 to the S-3, we are also filing an amendment to our Annual Report on Form 10-K for the year ended December 31, 2004 (the “2004 10-K/A”), as to which the Staff had previously commented but with respect to which the Staff had no, or very minor, comments in the Comment Letter. We have executed manually executed signature pages and consents prior to the time of the electronic filing.
For the Staff’s convenience, we are also enclosing six courtesy copies of our Form 10-K/A amending the 2004 10-K, three clean and three marked to show changes from the 2004 10-K.
The numbered paragraphs in this letter correspond to the consecutively numbered paragraphs in the Comment Letter. References to page numbers are to page numbers in the marked versions of the filing and proposed filing submitted to the Staff herewith.
RESPONSES TO COMMENTS
Comments to the Form S-3
Incorporation of Documents by Reference
1. The requested updated disclosure has been made on page 25 of the prospectus.
Exhibits
2. The additional exhibit requested by the Staff has been filed with Amendment No. 2 to the S-3.
If you need any additional information after reviewing the above, you can contact me on my cellular phone at 011-972-54-646-4808. You may also contact our outside counsel, Steven M. Skolnick, who can be reached at 1-973-597-2476.
Sincerely,
Yaakov
Har-Oz
Show Raw Text
CORRESP
1
filename1.htm
Arotech
Corporation
http://www.arotech.com
Nasdaq
National Market: ARTX
Writer’s
direct dial: +972-2-990-6623
Writer’s
direct fax: +972-2-990-6688
Writer’s
e-mail: yaakovh@arotech.com
Yaakov
Har-Oz
Vice
President and General Counsel
Admitted
in New York and Israel
August
15, 2005
VIA
EDGAR
Securities
and Exchange Commission
Filing
Desk, Stop 1-4
450
Fifth
Street, N.W.
Washington,
D.C. 20549
Attention:
Ms
Peggy Fisher, Assistant Director
Re:
Arotech
Corporation
Amendment
No. 1 to Registration Statement on Form S-3
Filed
July 20, 2005
File
No. 333-124961
Draft
of Amendment to Form 10-K for
Fiscal
Year Ended December 31, 2004
File
No. 0-23336
Dear
Ms
Fisher:
This
letter sets forth the responses of Arotech Corporation (“we” or the “Company”)
to the comments contained in the letter (the “Comment Letter”) of the staff of
the Securities and Exchange Commission (the “Staff”) dated August 2, 2005 and
addressed to Leland Nall, with respect to the filing by the Company of the
above-referenced registration statement (the “S-3”) on May 16,
2005.
We
filed
Amendment No. 1 to the S-3, in response to the Staff’s comments contained in its
comment letter of June 8, 2005, on July 20, 2005. We are hereby filing Amendment
No. 2 to our Form S-3. We have executed manually executed signature pages
and
consents prior to the time of the electronic filing. For the Staff’s
convenience, we are enclosing six courtesy copies of Amendment No. 2 to the
S-3;
three copies are clean, and three copies have been marked to show changes
from
the S-3. We are also enclosing three copies of this letter, containing the
Company’s responses to the Comment Letter.
Concurrent
with our filing of Amendment No. 2 to the S-3, we are also filing an amendment
to our Annual Report on Form 10-K for the year ended December 31, 2004 (the
“2004 10-K/A”), as to which the Staff had previously commented but with respect
to which the Staff had no, or very minor, comments in the Comment Letter.
We
have executed manually executed signature pages and consents prior to the
time
of the electronic filing.
For
the
Staff’s convenience, we are also enclosing six courtesy copies of our Form
10-K/A amending the 2004 10-K, three clean and three marked to show changes
from
the 2004 10-K.
The
numbered paragraphs in this letter correspond to the consecutively numbered
paragraphs in the Comment Letter. References to page numbers are to page
numbers
in the marked
versions
of the filing and proposed filing submitted to the Staff herewith.
RESPONSES
TO COMMENTS
Comments
to the Form S-3
Incorporation
of Documents by Reference
1. The
requested updated disclosure has been made on page 25 of the
prospectus.
Exhibits
2. The
additional exhibit requested by the Staff has been filed with Amendment No.
2 to
the S-3.
If
you
need any additional information after reviewing the above, you can contact
me on
my cellular phone at 011-972-54-646-4808. You may also contact our outside
counsel, Steven M. Skolnick, who can be reached at 1-973-597-2476.
Sincerely,
Yaakov
Har-Oz
Vice
President and General Counsel
cc: Kristin
Lochheed, Esq.
Gary
Todd, Esq.
Tom
Jones, Esq.
Robert
S.
Ehrlich
Steven
M.
Skolnick, Esq.
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