SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

                                                                 December 23, 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 response letter da ted December 15, 2010 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

 General

1. You have not provided the tandy language re quested in our previous comment letter
dated December 3, 2010.  In this regard, please  provide us with the following statements,
in writing, as signed by the company, acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in their
filings;
• 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.

Mr. James R. Buscemi
Hudson Technologies, Inc. December 23, 2010 Page 2  Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

 Liquidity and Capital Resources, page 15

2. We have read your response to prior comment  three.  The disclosu res suggested in the
guidance we referred to in our prior comment are intended to be forward-looking so that,
when it is reasonably likely th at a covenant may not be met, readers know of that
possibility and the surrounding circumstances pr ior to it actually ha ving occurred and can
see how close the covenant is to not being me t.  The suggested disclosures do not appear
to have been provided either in advance of your covenant violation requiring a waiver in
July 2009 or after the covenant  was violated and a waiver was required, so readers still
may not fully understand what caused the viol ation, exactly what the actual covenant
amount or ratio is in each period presented (with a reconc iliation to US GAAP amounts)
and how that compares to the required covena nt amount or ratio.  They also may not fully
understand the reasonable likelihood of the covenant  violation recurring in  future periods.
In addition, it is not clear from your proposed  disclosure whether you intend to provide
the suggested disclosure in future filings related to the minimum Adjusted EBITDA and
other material covenants.  If not, why not  for the minimum Adjusted EBITDA covenant,
in light of your recent covenant non-complia nce?  If so, please show us what your
proposed disclosures will look like.  Also, since EBITDA is not defined in US GAAP,
you should not imply that it is in your proposed disclosure.

Item 15. Exhibits, Financial Statement and Schedules, page 31

3. We note your response to prior comment si x of our letter dated December 13, 2010.
Please provide us supplementally with your analys is as to the materiality of the separate
agreements with Linde affiliates and the stra tegic alliance agreement with EOS Climate,
Inc.  If you believe that the agreements are no t material to your business, please consider
including appropriate disclosu re in your future filings to help investors place the
importance of these agreements in context .

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