SEC Company Response from HUDSON TECHNOLOGIES (HDSN) — Jan 17, 2013
HUDSON TECHNOLOGIES INC /NY (HDSN) (CIK 0000925528)
Date: Jan. 17, 2013 · CIK: 0000925528 · Accession: 0001144204-13-002823
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File numbers found in text: 333-185490
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CORRESP
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[HUDSON TECHNOLOGIES, INC. LETTERHEAD]
January 17, 2013
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: Hudson Technologies, Inc. (the “Company”)
Registration Statement on Form S-3
Filed December 14, 2012, as amended by Amendment
No. 1 Filed January 11, 2013
File No. 333-185490
Ladies and Gentlemen:
The Company hereby
requests that the above-referenced Registration Statement be declared effective on Tuesday, January 22, 2013, at 4:30 P.M., Eastern
Standard Time, or as soon thereafter as practicable.
In connection with
the foregoing acceleration request, the Company acknowledges that:
· should the Securities and Exchange Commission (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 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 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.
Very truly yours,
Hudson Technologies, Inc.
By: /s/ Brian F. Coleman
Name: Brian F. Coleman
Title: President, Chief Operating Officer