SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

                                                                 December 3, 2010
 Mr. James R. Buscemi Chief Financial Officer Hudson Technologies, Inc. 1 Blue Hill Plaza, Suite 1541 Pearl River, New York 10965
 RE: Hudson Technologies, Inc.
Form 10-K for the Year Ended December 31, 2009
Forms 10-Q for the Periods Ended March 31, 2010, June 30, 2010 and  September 30, 2010 File No. 1-13412

Dear Mr. Buscemi:

We have reviewed your 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 why in your response.
   After reviewing the information you provide  in response to these comments, we may
have additional comments.
Form 10-K for the Year Ended December 31, 2009

 Item 1. Business

 Products and Services

 RefrigerantSide® Services, page 4

1. Your disclosure under this heading that you have “been awarded four United States
patents for [your] Performance Optimization System” appears inconsistent with your
statement on page eight under th e heading “Patents and Propri etary Information” that you
“hold[] a United States patent….”  Please revise your disclosure accordingly in future filings.

Mr. James R. Buscemi
Hudson Technologies, Inc. December 3, 2010 Page 2  Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

 Liquidity and Capital Resources, page 15

2. In future filings, please consider revising your contractual obligations table to separately
disclose the amounts of your estimated inte rest payments for each period presented.
Please show us in your supplemental response what the revisions will look like.

3. In future filings, please disclose whethe r you were in compliance with your debt
covenants as of December 31, 2009.  Please disc lose the specific terms of any material
debt covenants with any required ratios/amount s.  For any material debt covenants for
which it is reasonably likely that you will not  be able to meet, such as your minimum
EBITDA covenant that you requi red a waiver for violati ng in July 2009, please also
disclose the actual ratios/amounts as of each reporting date and reconcile them to US
GAAP amounts.  If EBITDA as defined in the credit facility is  not computed as
commonly defined, please also retitle this measure to better c onvey that additional
adjustments are included.  One choice may be  to call it Adjusted EBITDA.  See Sections
I.D and IV.C of the SEC Interpretiv e Release No. 33-8350 and Compliance and
Disclosures Interpretation 102.09 whic h is available on our website at
http://www.sec.gov/divisions/cor pfin/guidance/nongaapinterp.htm .  Please show us in
your supplemental response what the revisions will look like.

Item 9A (T). Controls and Procedures
 Disclosure Controls and Procedures, page 19

4. We note your statement that “any controls and procedures, no matter how well designed
and operated, can provide only reasonable a ssurance of achieving the desired control
objectives….”  Please confirm to us, and revise accordingly in future filings to indicate,
that your disclosure controls and procedures  are effective at the reasonable assurance
level.  Alternatively, please remove the re ference to the level of assurance of your
disclosure controls and procedures.
 Item 11. Executive Compensation

 Summary Compensation Table, page 22

 5. Please confirm, if true, that  the option awards disclosed in your summary compensation
and director compensation tables reflect the a ggregate grant date fair value computed in
accordance with FASB ASC T opic 718.  See Items 402(n)(2)(vi) and (r)(2)(iv) of
Regulation S-K.

Mr. James R. Buscemi
Hudson Technologies, Inc. December 3, 2010 Page 3  Item 15. Exhibits, Financial Statement and Schedules, page 31

6. We note that you have not filed or incorpor ated by reference any of the items listed
below.
• Exclusive global technology and marke ting agreement with The Linde Group,
referenced on page five.
• Separate supplemental agreements with certain Linde affiliate companies covering
the United Kingdom and the Republic of S outh Africa, referenced on page five.
• Strategic alliance agreement with EOS Climate, Inc., referenced on page five.
• First Amendment to Restated Employment Agreement with Mr. Zugibe dated
December 29, 2008, referenced on page 22.
• First Amendment to Amended and Restated Loan Agreement with Keltic Financial
Partners, L.P.
In future filings, please file or incorporate by reference each of these agreements in accordance with Item 601(b)(10) of Regulati on S-K, or explain to us why you believe
each is not required to be filed.

7. It appears that you have omitted the schedules  and exhibits referenced in your Amended
and Restated Loan Agreement between H udson Technologies and Keltic Financial
Partners, L.P. dated June 26, 2007, incorporated  by reference as exhibit 10.16.  Please file
with your next Exchange Act report a comple te copy of this credit agreement, which
should include all schedules and exhibits re ferenced therein.  See Item 601(b)(10) of
Regulation S-K.
Exhibits 31.1 and 31.2

8. In future filings, please file your certifications as exactly set forth in  Item 601(b)(31)(i) of
Regulation S-K, without modifying the langu age in paragraphs 4(a), (b), and (d).

Form 10-Q for the Period Ended September 30, 2010
 General

 9. Please address the comments above in  your interim filings as well.

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
In responding to our comments, please provi de a written statement from the company
acknowledging that:

Mr. James R. Buscemi
Hudson Technologies, Inc. December 3, 2010 Page 4
• the company is responsible for the adequacy an d accuracy of the disclo sure 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.
 You may contact Hagen Ganem, Staff Atto rney, at (202) 551-3330 or Pamela Long,
Assistant Director at (202) 551- 3760 if you have any questions regarding legal matters.  Please
contact Ernest Greene, Staff Accountant at (202) 551-3733 or me at (202) 551-3769 if you have
questions regarding comments on the financ ial statements and related matters.
          Sincerely,            R u f u s  D e c k e r
       Accounting Branch Chief