SEC Comment Letter for HUDSON TECHNOLOGIES (HDSN) — Mar 28, 2018
HUDSON TECHNOLOGIES INC /NY (HDSN) (CIK 0000925528)
Date: March 28, 2018 · CIK: 0000925528 · Accession: 0000000000-18-009382
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-223755
Letter
Mail Stop 4631 March 27, 2018 Kevin J. Zugibe Chairman and Chief Executive Officer 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 March 19, 2018 File No. 333-223755
Dear Mr. Zugibe :
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 . If you do not believe our com ments 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, w e may have additional comments.
General
1. We note that Part III of your annual report on Form 10 -K for the fiscal year ended December 31, 2017 incorporates by reference portions of your definitive proxy statement which has not been filed yet. Please be advised that we cannot accelerate the effective date of your registration statement until you have amended the Form 10 -K to include Part III information or filed the definitive proxy statement. For guidance, please refer to Compliance and Disclosure Inter pretations, Securities Act Forms Questions 123.01, available on the Commission’s website.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Kevin J. Zugibe Hudson Technologies, Inc. March 27, 2018 Page 2
Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
Please contact Sergio Chinos, Staff Attorney , at (202) 551 -7844 or me at (202) 551 -3765 with any other questions.
Sincerely,
/s/ Pamela A. Long
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Mail Stop 4631 March 27, 2018 Kevin J. Zugibe Chairman and Chief Executive Officer 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 March 19, 2018 File No. 333-223755 Dear Mr. Zugibe : 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 . If you do not believe our com ments 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, w e may have additional comments. General 1. We note that Part III of your annual report on Form 10 -K for the fiscal year ended December 31, 2017 incorporates by reference portions of your definitive proxy statement which has not been filed yet. Please be advised that we cannot accelerate the effective date of your registration statement until you have amended the Form 10 -K to include Part III information or filed the definitive proxy statement. For guidance, please refer to Compliance and Disclosure Inter pretations, Securities Act Forms Questions 123.01, available on the Commission’s website. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Kevin J. Zugibe Hudson Technologies, Inc. March 27, 2018 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Sergio Chinos, Staff Attorney , at (202) 551 -7844 or me at (202) 551 -3765 with any other questions. Sincerely, /s/ Pamela A. Long Pamela A. Long Assistant Director Office of Manufacturing and Construction cc: Michael Grundei, Esq.