SEC Comment Letter for INSIGHT HEALTH SERVICES HOLDINGS CORP (CIK 0001145238) — Nov 16, 2004
INSIGHT HEALTH SERVICES HOLDINGS CORP (CIK 0001145238)
Date: Nov. 16, 2004 · CIK: 0001145238 · Accession: 0000000000-04-036741
AI Filing Summary & Sentiment
File numbers found in text: 333-120199
Show Raw Text
<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> Mail Stop 0309 November 16, 2004 Marilyn U. MacNiven-Young, Esq. Executive Vice President and General Counsel InSight Health Services Corp. 26250 Enterprise Court, Suite 100 Lake Forest, California 92630 Re: InSight Health Services Corp. Registration Statement on Form S-4 File Number 333-120199 Dear Ms. MacNiven-Young: This is to advise you that we are not conducting a full review of the above registration statement. However, you will need to resolve all issues that arise during our ongoing review of your Form 10-K for the period ended June 30, 2004 before we take final action on the registration statement. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an informed decision. 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. Notwithstanding our comments, in the event the company requests acceleration of the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that: * should 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 this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing. We will consider a written request for acceleration of the effective date of the registration statement as a confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. We will act on the request and, pursuant to delegated authority, grant acceleration of the effective date. Please contact Greg Belliston at (202) 824-5219 or me at (202) 942-1840 with any questions. Sincerely, Jeffrey P. Riedler Assistant Director cc: Stephen C. Koval, Esq. Kaye Scholer LLP 425 Park Avenue New York, New York 10022 Marilyn U. MacNiven-Young, Esq. InSight Health Services Corp. November 16, 2004 Page 1 </TEXT> </DOCUMENT>