SecProbe.io

January 8 , 2013

Via E -mail
Stephen P. Mandracchia
Vice -President Legal and Regulatory
Hudson Technologies, Inc.
P.O. Box 1541
One Blue Hill Plaza
Pearl River, NY 10965

Re: Hudson Technologies,  Inc.
  Registration Statement on Form S-3
Filed  December 14, 2012
  File No.  333-185490

Dear Mr. Mandracchia :

We have limited our review of your registration statement to those issues we have
addressed in our 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 by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

Registration Statement on Form S -3

Selling Shareholders, page 4

1. Please disclose how the selling shareholders  acquired the securities they may offer and
sell pursuant to the registration statement, including the dates of the transactions, the
number of shares purchased in each transaction, and the purchase price, if any.

Description of Debt Securities, page 10

2. We note your disclosure that any debt securities you offer will be exempt under the Trust
Indenture Act.  Please advise us as to the exemption that you intend to rely upon in
issuing the debt securities.

Stephen P. Mandracchia
Hudson Technologies, Inc.
January 8 , 2013
Page 2

 We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts rel ating 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 you request acceleration of the effective date
of the pending registration statement please  provide a written statement from the company
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 fil ing;

 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 staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding request s for acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as 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.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Erin Jaskot, Staff Attorney  at 202-551-3442 , Craig Slivka, Special
Counsel,  at 202-551-3729 with any questions.

Sincerely,

 /s/ Craig E. Slivka, for

Pamela A. Long
Assistant Director

cc: Richard DiStefano , Esq. ( via E-mail)
 Blank Rome  LLP