SEC Company Response from HUDSON TECHNOLOGIES (HDSN) — Apr 2, 2018
HUDSON TECHNOLOGIES INC /NY (HDSN) (CIK 0000925528)
Date: April 2, 2018 · CIK: 0000925528 · Accession: 0001144204-18-018406
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-223755
Referenced dates: March 27, 2018
Letter
VIA EDGAR United States Securities and Exchange Commission Re: Hudson Technologies, Inc. Registration Statement on Form S-3 Filed March 19, 2018 File No. 333-223755
Dear Ms. Long:
We are in receipt of your letter dated March 27, 2018, which contained comments regarding our Registration Statement on Form S-3 filed on March 19, 2018. Listed below is a specific response to your numbered comment.
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 Interpretations, Securities Act Forms Questions 123.01, available on the Commission’s website.
Response: In accordance with the staff’s comment, we will defer the acceleration of the effectiveness of the above-referenced registration statement until after we have amended the Form 10-K to include Part III information or filed the definitive proxy statement.
If you have any further questions regarding our response to your comments, please do not hesitate to call our counsel, Michael Grundei of Wiggin and Dana LLP, at 203-363-7630, or the undersigned at 845-735-6000.
Sincerely,
/s/ Kevin J. Zugibe
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CORRESP
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HUDSON TECHNOLOGIES, INC.
P.O. Box 1541
One Blue Hill Plaza
Pearl River, NY 10965
845-735-6000 (Phone)
April 2, 2018
VIA EDGAR
Ms. Pamela A. Long
Assistant Director
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re:
Hudson Technologies, Inc.
Registration Statement on Form S-3
Filed March 19, 2018
File No. 333-223755
Dear Ms. Long:
We are in receipt of your letter dated March 27, 2018, which
contained comments regarding our Registration Statement on Form S-3 filed on March 19, 2018. Listed below is a specific response
to your numbered comment.
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 Interpretations, Securities Act Forms Questions 123.01,
available on the Commission’s website.
Response:
In accordance with the staff’s comment, we will defer the acceleration of the effectiveness of the above-referenced
registration statement until after we have amended the Form 10-K to include Part III information or filed the definitive proxy
statement.
If you have any further questions regarding our response to
your comments, please do not hesitate to call our counsel, Michael Grundei of Wiggin and Dana LLP, at 203-363-7630, or the undersigned
at 845-735-6000.
Sincerely,
/s/ Kevin J. Zugibe
Kevin J. Zugibe
Chairman and Chief Executive Officer
cc:
Nat Krishnamurti (Hudson Technologies, Inc.)
Michael Grundei (Wiggin and Dana LLP)
Sergio Chinos (Securities and Exchange Commission)
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