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CORRESP
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      Unassociated Document

    HUDSON
      TECHNOLOGIES, INC.

    P.O.
      Box
      1541

    One
      Blue
      Hill Plaza

    Pearl
      River, New York 10965

    September
      3, 2008

    VIA
      EDGAR AND FACSIMILE

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

              Re:

              Hudson
                Technologies, Inc.

    Registration
      Statement on Form S-3

    SEC
      File No. 333-151973

    Ladies
      and Gentlemen:

    Pursuant
      to Rule 461(a) under the Securities Act of 1933, as amended, it is hereby
      requested that the effective date of the above-referenced Registration Statement
      on Form S-3 (the “Registration Statement”) of Hudson Technologies, Inc. (the
“Company”) be accelerated and that the Registration Statement become effective
      at 4:30 P.M. on Friday, September 5, 2008, or as soon thereafter as
      practicable.

    In
      connection with the foregoing acceleration request, the Company acknowledges
      that:

          ·

            should
              the United States Securities and Exchange Commission (“Commission”) or its
              staff, acting pursuant to delegated authority, declare the Registration
              Statement effective, it does not foreclose the Commission from taking
              any
              action with respect to the Registration
              Statement;

          ·

            the
              action of the Commission or its staff, acting pursuant to delegated
              authority, in declaring the Registration Statement effective, does
              not
              relieve the Company from its full responsibility for the accuracy and
              adequacy of the disclosure in the Registration Statement;
              and

          ·

            the
              Company may not assert staff comments and the declaration of effectiveness
              of the Registration Statement as a defense in any proceeding initiated
              by
              the Commission or any person under the federal securities laws of the
              United States.

              Very
                truly yours,

              HUDSON
                TECHNOLOGIES, INC.

              By:

                /s/
                Kevin J. Zugibe

              Name:
                Kevin J. Zugibe

              Title:
                Chief Executive Officer