SEC Comment Letter for HUDSON TECHNOLOGIES (HDSN) — Jan 21, 2011
HUDSON TECHNOLOGIES INC /NY (HDSN) (CIK 0000925528)
Date: Jan. 21, 2011 · CIK: 0000925528 · Accession: 0000000000-11-004265
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 7, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE January 20, 2011 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 dated January 7, 2011 and have the following comment. Please respond to this letter with in ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provi de in response to this comment, we may have additional comments.
Form 10-K for the Year Ended December 31, 2009
Management’s Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 15
1. We have read your response to pr ior comment two. Please revise your proposed disclosure to include a reco nciliation of Adjusted EBITDA to the most comparable US GAAP amount for each period presented. Please show us what your proposed disclosures will look like.
Mr. James R. Buscemi Hudson Technologies, Inc. January 20, 2011 Page 2 You may contact Hagen Gane m, Staff Attorney, at (202) 551-3330 or Pamela Long, Assistant Director at (202) 551-3760 if you have any questions regarding legal matters. Please contact Erne st Greene, Staff Accountant at (202) 551-3733 or me at (202) 551-3769 if you have questions regarding comments on the financial statements and related matters. Sincerely, R u f u s D e c k e r Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
January 20, 2011
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 dated January 7, 2011 and have the
following comment.
Please respond to this letter with in ten business days by providing the
requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances,
please tell us why in your response. After reviewing the information you provi de in response to this comment, we
may have additional comments.
Form 10-K for the Year Ended December 31, 2009
Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 15
1. We have read your response to pr ior comment two. Please revise your
proposed disclosure to include a reco nciliation of Adjusted EBITDA to the
most comparable US GAAP amount for each period presented. Please show us what your proposed disclosures will look like.
Mr. James R. Buscemi
Hudson Technologies, Inc. January 20, 2011 Page 2
You may contact Hagen Gane m, Staff Attorney, at (202) 551-3330 or Pamela
Long, Assistant Director at (202) 551-3760 if you have any questions regarding legal
matters. Please contact Erne st Greene, Staff Accountant at (202) 551-3733 or me at
(202) 551-3769 if you have questions regarding comments on the financial
statements and related matters. Sincerely, R u f u s D e c k e r
Accounting Branch Chief