SEC Comment Letter for HUDSON TECHNOLOGIES (HDSN) — Dec 10, 2015
HUDSON TECHNOLOGIES INC /NY (HDSN) (CIK 0000925528)
Date: Dec. 10, 2015 · CIK: 0000925528 · Accession: 0000000000-15-057324
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-207969
Letter
Mail Stop 4631 December 10, 2015 Via E -mail James Buscemi Chief Financial Officer Hudson Technologies, Inc. P.O. Box 1541 One Blue Hill Plaza Pearl River, New York 10965
Re: Hudson Technologies, Inc. Registration Statement on Form S-3 Filed November 12, 2015 File No. 333-207969
Dear Mr. Buscemi :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy 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 relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In the event you request acceleration of the effective date of the pending regist ration 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 wit h respect to the filing;
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 th e 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.
James Buscemi Hudson Technologies, Inc. December 10, 2015 Page 2
Please refer to Rules 460 and 4 61 regarding requests 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 u nder the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
Please contact Chris Ronne, Staff Attorney at (202) 551 -6156 or, in his absence, Jay Ingram, Legal Branch Chief at (202) 551 -3397 with any questions.
Sincerely,
/s/ Jay Ingram
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Mail Stop 4631 December 10, 2015 Via E -mail James Buscemi Chief Financial Officer Hudson Technologies, Inc. P.O. Box 1541 One Blue Hill Plaza Pearl River, New York 10965 Re: Hudson Technologies, Inc. Registration Statement on Form S-3 Filed November 12, 2015 File No. 333-207969 Dear Mr. Buscemi : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy 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 relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In the event you request acceleration of the effective date of the pending regist ration 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 wit h respect to the filing; 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 th e 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. James Buscemi Hudson Technologies, Inc. December 10, 2015 Page 2 Please refer to Rules 460 and 4 61 regarding requests 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 u nder the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . Please contact Chris Ronne, Staff Attorney at (202) 551 -6156 or, in his absence, Jay Ingram, Legal Branch Chief at (202) 551 -3397 with any questions. Sincerely, /s/ Jay Ingram Jay Ingram Legal Branch Chief Office of Manufacturing and Construction Cc: Via E -mail Michael Grundei, Esq.