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SEC Comment Letter for SIGA TECHNOLOGIES (SIGA) — Oct 1, 2010

SIGA TECHNOLOGIES INC
Date: Oct. 1, 2010 · CIK: 0001010086 · Accession: 0000000000-10-058182

AI Filing Summary & Sentiment

File numbers found in text: 000-23047

Date
October 1, 2010
Author
Tabatha Akins
Form
UPLOAD
Company
SIGA TECHNOLOGIES INC

Letter

October 1, 2010 Ayelet Dugary Chief Financial Officer SIGA Technologies, Inc. 35 East 62nd Street New York, N Y 10065

Re: SIGA Technologies, Inc. Form 8-K Filed September 28, 2010 File No. 000-23047

Dear Mr s. Dugary :

We have reviewed your filing an d have the following comments.

Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response . If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may have additional comments and/or request that you amend your filing.

Form 8-K Item 4.02(a) Non -Reliance on Previously Issued Financial Statements or Related Audit Report or Completed Interim Report. , page 2

1. Please tell us whether you will reconsider, in accordance with Item 307 of Regulation S -K, the adequacy of your previous assertions in your consolidated financial statements for the years ended December 31, 2009 and 2008, and the quarte rly periods from June 30, 2008 through June 30, 2010 regarding your disclosure controls and procedures, in light of the material errors that you have described.

2. Please also provide us with an estimated time -frame as to when you intend to file the amended Form 10 -K and Forms 10 -Q for the periods discussed in this filing.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Sec urities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

Ayelet Dugary SIGA Technologies, Inc. October 1, 2010 Page 2

In responding to our comment s, please provide a written statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comment s or changes to disclosure in res ponse to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

the company may not assert staff comment s as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions, please do not hesitate to call me at (202) 551 -3658.

Sincerely,
Tabatha Akins
Staff Accountant

Show Raw Text
October  1, 2010

Ayelet Dugary
Chief Financial Officer
SIGA Technologies, Inc.
35 East 62nd Street
New York, N Y  10065

Re: SIGA Technologies, Inc.
 Form 8-K
Filed September  28, 2010
File No. 000-23047

Dear Mr s. Dugary :

We have reviewed your filing an d have the following comments.

Please respond to this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response .  If you do not
believe our comment appl ies to your facts and circumstances or do not believe an amendment is
appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have additional comments and/or request that you amend your filing.

Form 8-K
Item 4.02(a) Non -Reliance on Previously Issued Financial Statements or Related Audit Report or
Completed Interim Report. , page 2

1. Please  tell us whether you will reconsider, in accordance with Item 307 of Regulation S -K,
the adequacy of your previous assertions in your consolidated financial statements for the
years ended December 31, 2009 and 2008, and the quarte rly periods from June 30, 2008
through June 30, 2010 regarding your disclosure controls and procedures, in light of the
material errors that you have described.

2. Please also provide us with an estimated time -frame as to when you intend to file the
amended Form 10 -K and Forms 10 -Q for the periods discussed in this filing.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Sec urities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Ayelet Dugary
SIGA Technologies, Inc.
October  1, 2010
Page 2

 In responding to our comment s, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comment s or changes to disclosure in res ponse to staff comments do not foreclose
the Commission from taking  any action with respect to the filing; and

 the company may not assert staff comment s as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

If you have any questions, please do not hesitate to call me at (202) 551 -3658.

       Sincerely,

       Tabatha Akins
       Staff Accountant