SEC Comment Letter for MIND TECHNOLOGY, INC (MIND) (CIK 0000926423) (MIND) — May 6, 2011
MIND TECHNOLOGY, INC (MIND) (CIK 0000926423)
Date: May 6, 2011 · CIK: 0000926423 · Accession: 0000000000-11-028403
AI Filing Summary & Sentiment
File numbers found in text: 333-172935
Letter
Re: Mitcham Industries, Inc. Amendment No. 1 to Registration Statement on Form S -3 Filed April 25 , 2011 File No. 333-172935 Dear Mr. Mitcham : We have limited our review of your registration statement to those issues we have addressed in our comment .
Via U.S. Mail and facsimile (713/615- 5794) May 6 , 2011
Billy F. Mitcham, Jr. President and Chief Executive Officer Mitcham Industries, Inc. 8141 SH 75 South, P.O. Box 1175 Huntsville, Texas 77342
General 1. Please be advised that you must either file your definitive proxy statement or amend your Form 10- K for the fiscal year ended January 31, 2011 to include Part III information and clear any outstanding Staff comments on your Form 10- K and proxy statement before you may request to accelerate the effectiveness of your registration statement. See Question 123.01 of the Securities Act Forms Compliance and Disclosure Interpretations which is available on our website and may be found at http://www.sec.gov/divisions/corpfin/guidance/safinterp.htm . Please contact Sherry Haywood, Staff Attorney at (202) 551- 3345 or , in her absence, me at (202) 551- 3397 wit h any questions.
Sincerely,
Jay Ingram
Legal Branch Chief
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Via U.S. Mail and facsimile (713/615- 5794) May 6 , 2011 Billy F. Mitcham, Jr. President and Chief Executive Officer Mitcham Industries, Inc. 8141 SH 75 South, P.O. Box 1175 Huntsville, Texas 77342 Re: Mitcham Industries, Inc. Amendment No. 1 to Registration Statement on Form S -3 Filed April 25 , 2011 File No. 333-172935 Dear Mr. Mitcham : We have limited our review of your registration statement to those issues we have addressed in our comment . General 1. Please be advised that you must either file your definitive proxy statement or amend your Form 10- K for the fiscal year ended January 31, 2011 to include Part III information and clear any outstanding Staff comments on your Form 10- K and proxy statement before you may request to accelerate the effectiveness of your registration statement. See Question 123.01 of the Securities Act Forms Compliance and Disclosure Interpretations which is available on our website and may be found at http://www.sec.gov/divisions/corpfin/guidance/safinterp.htm . Please contact Sherry Haywood, Staff Attorney at (202) 551- 3345 or , in her absence, me at (202) 551- 3397 wit h any questions. Sincerely, Jay Ingram Legal Branch Chief Billy F. Mitcham, Jr. Mitcham Industries, Inc. May 6 , 2011 Page 2 cc: Gillian A. Hobson ( Via facsimile 713/615- 5794) Vinson & Elkins L.L.P. First City Tower 1001 Fannin Street, Suite 2500 Houston, Texas 77002