SecProbe.io

CORRESP
 1
 filename1.htm

 dyai20250328_corresp.htm

 March 31, 2025

 Office of Life Sciences

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re:

 REQUEST FOR ACCELERATION OF EFFECTIVENESS

 Dyadic International, Inc. (CIK No. 0001213809)

 Registration Statement on Form S-3

 File No. 333-286121

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Dyadic International, Inc. (the “ Company ”), hereby requests that the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-286121) (the “ Registration Statement ”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 4:00 p.m., Eastern Time, on April 2, 2025, or as soon as practicable thereafter.

 Should you have any questions regarding this letter, please do not hesitate to contact Kimberly Petillo-Decossard at (212) 819-8398 or Jessica Y. Chen at (212) 819-8503 of White & Case LLP, counsel to the Company.

 Sincerely yours,

 Dyadic International, Inc.

 By:

 /s/ Ping Rawson

 Name: Ping Rawson

 Title: Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 28, 2025

Mark Emalfarb
Chief Executive Officer and Director
Dyadic International, Inc.
1044 North U.S. Highway One, Suite 201
Jupiter, FL 33477

 Re: Dyadic International, Inc.
 Registration Statement on Form S-3
 Filed March 26, 2025
 File No. 333-286121
Dear Mark Emalfarb:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Daniel Crawford at 202-551-7767 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Jessica Y. Chen, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

	dyai20240503_corresp.htm

May 3, 2024

Office of Life Sciences

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

			Re:

			REQUEST FOR ACCELERATION OF EFFECTIVENESS

			Dyadic International, Inc. (CIK No. 0001213809)

			Registration Statement on Form S-3

			File No. 333-278916

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Dyadic International, Inc. (the “Company”), hereby requests that the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-278916) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 4:00 p.m., Eastern Daylight Time, on May 7, 2024, or as soon as practicable thereafter.

Should you have any questions regarding this letter, please do not hesitate to contact Kimberly Petillo-Decossard at (212) 819-8398 or Jessica Y. Chen at (212) 819-8503 of White & Case LLP, counsel to the Company.

			Sincerely yours,

			Dyadic International, Inc.

			By:

			/s/ Ping Rawson

			Name: Ping Rawson

			Title: Chief Financial Officer

United States securities and exchange commission logo
April 30, 2024
Mark Emalfarb
Chief Executive Officer
Dyadic International, Inc.
1044 North U.S. Highway One, Suite 201
Jupiter, FL 33477
Re:Dyadic International, Inc.
Registration Statement on Form S-3
Filed April 24, 2024
File No. 333-278916
Dear Mark Emalfarb:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Daniel Crawford at 202-551-7767 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Jessica Chen, Esq.

CORRESP
1
filename1.htm

	dyai20230822_corresp.htm

August 23, 2023

VIA EDGAR

Office of Life Sciences

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

			Re:

			REQUEST FOR ACCELERATION OF EFFECTIVENESS

Dyadic International, Inc. (CIK No. 0001213809)

Registration Statement on Form S-3

File No. 333-273829

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Dyadic International, Inc. (the “Company”), hereby requests that the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-273829) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 4:00 p.m., Eastern Daylight Time, on August 25, 2023, or as soon as practicable thereafter.

Should you have any questions regarding this letter, please do not hesitate to contact Kimberly Petillo-Decossard at (212) 819-8398 of White & Case LLP, counsel to the Company.

			Sincerely yours,

			Dyadic International, Inc.

			By:

			/s/ Ping Rawson

			Name: Ping Rawson

			Title: Chief Financial Officer

United States securities and exchange commission logo
August 10, 2023
Ping Rawson
Chief Financial Officer
Dyadic International, Inc.
140 Intracoastal Pointe Drive, Suite 404
Jupiter, Florida 33477
Re:Dyadic International, Inc.
Registration Statement on Form S-3
Filed August 9, 2023
File No. 333-273829
Dear Ping Rawson:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Tim Buchmiller at (202) 551-3635 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Kimberly C. Petillo-Décossard, Esq.

United States securities and exchange commission logo
August 21, 2020
Mark Emalfarb
Chief Executive Officer
Dyadic International, Inc.
140 Intracoastal Pointe Drive, Suite 404
Jupiter, Florida 33477
Re:Dyadic International, Inc.
Registration Statement on Form S-3
Filed August 13, 2020
File No. 333-245687
Dear Mr. Emalfarb:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Chris Edwards at (202) 551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Kimberly C. Petillo-Décossard

CORRESP
1
filename1.htm

Document

Dyadic International, Inc.

140 Intracoastal Pointe Drive

Suite 404

Jupiter, Florida 33477

August 21, 2020

Via EDGAR Transmission

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3010

100 F Street, N.E.

Washington, D.C.  20549

Attention:  Chris Edwards

  Re: Dyadic International, Inc.

  Registration Statement on Form S-3 (Registration No. 333-245687)

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 (Registration No. 333-245687) (the “Registration Statement”) of Dyadic International, Inc. (the “Company”).  We respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on August 25, 2020, or as soon as practicable thereafter.  Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Cahill Gordon & Reindel LLP, by calling Kimberly C. Petillo-Decossard at (212) 701-3265.

If you have any questions regarding the foregoing, please do not hesitate to contact Kimberly C. Petillo-Decossard of Cahill Gordon & Reindel LLP at (212) 701-3265. Thank you in advance for your consideration.

Very truly yours,

Dyadic International, Inc.

By: /s/ Mark Emalfarb

Name: Mark Emalfarb

Title: Chief Executive Officer

cc:  Kimberly C. Petillo-Decossard, Cahill Gordon & Reindel LLP

CORRESP
1
filename1.htm

		Document

Dyadic International, Inc.

140 Intracoastal Pointe Drive

Suite 404

Jupiter, FL 33477

February 12, 2019

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-4628

Attention:

 Amanda Ravitz

Assistant Director

Division of Corporate Finance

Office of Manufacturing and Construction

Re:

 Dyadic International, Inc.

Registration Statement on Form 10

File No. 000-55264 (the “Registration Statement”)

Dear Sirs:

Pursuant to Section 12(g)(1) promulgated under the Securities Exchange Act of 1934, as amended, Dyadic International, Inc. hereby respectfully requests acceleration of the effective date of the Registration Statement so that it may become effective at 4:00 p.m., Eastern Time, on February 12, 2019, or as soon thereafter as practicable.

Should any member of the staff of the Commission have any questions or comments with respect to this request, please contact our counsel, Cahill Gordon & Reindel LLP, attention: Kimberly C. Petillo-Decossard at (212) 701-3265.

Very truly yours,

DYADIC INTERNATIONAL, INC.

By:

 /s/ Ping W. Rawson

 Ping W. Rawson

 Chief Accounting Officer

cc:

 Edward M. Kelly

Asia Timmons-Pierce

February 12, 2019
Ping H. Rawson
Chief Accounting Officer
Dyadic International, Inc.
140 Intracoastal Pointe Drive, Suite 404
Jupiter, FL 33477
Re:Dyadic International, Inc.
Registration Statement on Form 10
Filed January 14, 2019
File No. 0-55264
Dear Ms. Rawson:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action, or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

February 7, 2019
Ping H. Rawson
Chief Accounting Officer
Dyadic International, Inc.
140 Intracoastal Pointe Drive, Suite 404
Jupiter, FL 33477
Re:Dyadic International, Inc.
Registration Statement on Form 10
Filed January 14, 2019
File No. 0-55264
Dear Ms. Rawson:
            We have reviewed your filing and have the following comments.  In some of our
comments we may ask you to provide us information so that we may better understand your
disclosure.
            Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe that
our comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Registration Statement on Form 10 filed January 14, 2019
Exclusive Forum Provision, page 60
1.We note your response to comment 5 of our letter dated December 3, 2018 and reissue our
comment.  We note that your forum selection provision identifies the Court of Chancery
of the State of Delaware as the exclusive forum for certain litigation, including any
"derivative action."  Please disclose whether this provision applies to actions arising under
the Securities Act or Exchange Act.  In that regard, we note that Section 27 of the
Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce any
duty or liability created by the Exchange Act or the rules and regulations under it, and
Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts
over all suits brought to enforce any duty or liability created by the Securities Act or the
rules and regulations under it.  If this provision does not apply to actions arising under the
Securities Act or Exchange Act, please ensure that the exclusive forum provision in the

 FirstName LastNamePing H. Rawson
 Comapany NameDyadic International, Inc.
 February 7, 2019 Page 2
 FirstName LastName
Ping H. Rawson
Dyadic International, Inc.
February 7, 2019
Page 2
governing documents states this clearly.  If the provision applies to Securities Act claims,
please revise your disclosures to disclose this information and to state that there is
uncertainty as to whether a court would enforce such provision, and to state that
stockholders will not be deemed to have waived the company’s compliance with the
federal securities laws and the rules and regulations under it.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Melinda J. Hooker, Staff Accountant, at (202) 551-3732 or W. John
Cash, Accounting Branch Chief, at (202) 551-3768 if you have questions regarding comments on
the financial statements and related matters.  Please contact Edward M. Kelly, Senior Counsel, at
(202) 551-3728 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
1
filename1.htm

		Document

 Dyadic International, Inc.

140 Intracoastal Pointe Drive, Suite 404

Jupiter, FL  33477

Tel: 561-743-8333

Fax: 561-743-8343

www.dyadic.com

February 8, 2019

VIA EDGAR AND FEDERAL EXPRESS

Amanda Ravitz

Assistant Director

Division of Corporation Finance

Office of Manufacturing and Construction

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549-3628

Re:

 Dyadic International, Inc.

Form 10-12G

Filed January 14, 2019

File No. 000-55264

Dear Ms. Ravitz:

On behalf of Dyadic International, Inc., a Delaware corporation (the “Company”), this letter sets forth the Company’s responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission” or the “SEC”) set forth in your letter dated February 7, 2019 (the “Comment Letter”), regarding the above referenced Registration Statement on Form 10-12G (the “Registration Statement”). The Company has also revised the Registration Statement in response to the Staff’s comments and is filing concurrently with this letter Amendment No. 1 to the Registration Statement (“Amendment No. 1”), which reflects these revisions.

For the convenience of the Staff, the comment from the Comment Letter corresponds to the numbered paragraph in the Comment Letter and is restated in italics prior to the response to such comment. Capitalized terms used and not defined have the meanings given in Amendment No. 1. Page and caption references in the text of this letter correspond to pages and captions in Amendment No. 1.

REGISTRATION STATEMENT ON FORM 10-12G

1.

 We note your response to comment 5 of our letter dated December 3, 2018 and reissue our comment. We note that your forum selection provision identifies the Court of Chancery of the State of Delaware as the exclusive forum for certain litigation, including any "derivative action." Please disclose whether this provision applies to

actions arising under the Securities Act or Exchange Act. In that regard, we note that Section 27 of the Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or liability created by the Exchange Act or the rules and regulations under it, and Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all suits brought to enforce any duty or liability created by the Securities Act or the rules and regulations under it. If this provision does not apply to actions arising under the Securities Act or Exchange Act, please ensure that the exclusive forum provision in the governing documents states this clearly. If the provision applies to Securities Act claims, please revise your disclosures to disclose this information and to state that there is uncertainty as to whether a court would enforce such provision, and to state that stockholders will not be deemed to have waived the company’s compliance with the federal securities laws and the rules and regulations under it.

Response:

In response to the Staff’s comment, the Company has revised its disclosure on pages 25 and 58 of Amendment No. 1 and has revised the forum selection provision contained in its Second Amended and Restated Bylaws attached as Exhibit 3.2 to Amendment No. 1 to be consistent with that disclosure.

***

The Company hereby acknowledges 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 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.

We appreciate the Staff’s comments and request the Staff contact the undersigned at (561) 743-8333 or prawson@dyadic.com with any questions or comments regarding this letter.

Sincerely,

/s/Ping Rawson

Ping W. Rawson

Chief Accounting Officer

cc:

Mark Emalfarb (Dyadic International, Inc.)

Kimberly Petillo-Décossard (Cahill Gordon & Reindel LLP)

CORRESP
1
filename1.htm

		Document

 Dyadic International, Inc.

140 Intracoastal Pointe Drive, Suite 404

Jupiter, FL  33477

Tel: 561-743-8333

Fax: 561-743-8343

www.dyadic.com

December 18, 2018

VIA EDGAR AND FEDERAL EXPRESS

Amanda Ravitz

Assistant Director

Division of Corporation Finance

Office of Manufacturing and Construction

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549-3628

Re:

 Dyadic International, Inc.
Form 10-12G
Filed November 5, 2018
File No. 000-55264

Dear Ms. Ravitz:

On behalf of Dyadic International, Inc., a Delaware corporation (the “Company”), this letter sets forth the Company’s responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission” or the “SEC”) set forth in your letter dated December 3, 2018 (the “Comment Letter”), regarding the above referenced Registration Statement on Form 10-12G (the “Registration Statement”). The Company has also revised the Registration Statement in response to the Staff’s comments and is filing concurrently with this letter Amendment No. 1 to the Registration Statement (“Amendment No. 1”), which reflects these revisions.

For the convenience of the Staff, each comment from the Comment Letter corresponds to the numbered paragraph in the Comment Letter and is restated in italics prior to the response to such comment. Capitalized terms used and not defined have the meanings given in Amendment No. 1. Page and caption references in the text of this letter correspond to pages and captions in Amendment No. 1.

REGISTRATION STATEMENT ON FORM 10-12G

Other Market Opportunities, page 9

1.

 Please identify the parties with whom you have entered into the two funded proof of concept research collaborations and file the agreements as exhibits.

Response:

The Company acknowledges the Staff’s comment and that Item 601(b)(10) of Regulation S-K requires, among other things, that a registrant file as an exhibit any agreement “not made in the ordinary course of business which is material to the registrant”, as well as any agreement, regardless of whether or not such agreement is ordinary course, upon which the registrant’s business is “substantially dependent”, unless immaterial in amount or significance. The Company respectfully submits that the proof of concept research collaborations do not meet the requirements of Item 601(b)(10) of Regulation S-K, and therefore are not required to be filed as an exhibit.  In addition, in response to the Staff’s comment, the Company believes that the above referenced proof of concept collaborations are not material to the Company’s business.

Risks Related to the Potential Reverse Stock Split…, page 27

2.

 Please disclose the range of the reverse stock split ratios that your shareholders approved and disclose any other material provisions of the stock split.

Response:

In response to the Staff’s comment, the Company has revised its disclosure on page 27 of Amendment No. 1.

Item 13. Financial Statements and Supplementary Data, page 60

3.

 Please update the disclosures and financial statements in order to comply with Rule 8-08 of Regulation S-X.

Response:

In response to the Staff’s comment and in order to comply with Rule 8-08 of Regulation S-X, we have included interim financial statements and disclosures for the period ended September 30, 2018 in Amendment No. 1.

General Comments

4.

 Please be advised that your registration statement will automatically become effective 60 days after the initial filing date. Upon effectiveness, you will become subject to the reporting requirements of the Securities Exchange Act of 1934, even if we have not cleared comments. If you do not wish to incur those obligations until you have cleared comments, you may wish to consider withdrawing your registration statement before it becomes effective automatically and submitting a new registration statement when you respond to our comments.

Response:

We acknowledge the Staff’s comment and confirm that we are aware that the Form 10-12G will become effective by operation of law 60 days from the initial filing, and that, following effectiveness, the Company will be responsible for filing reports required by Section 13 of the Exchange Act of 1934, even if the Staff has not completed the review process of the filing.

5.

 We note that your forum selection provision identifies the Court of Chancery of the State of Delaware as the exclusive forum for certain litigation, including any “derivative action.” Please disclose whether this provision applies to actions arising under the Securities Act or Exchange Act. In that regard, we note that Section 27 of the Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or liability created by the Exchange Act or the rules and regulations thereunder. If this provision does not apply to actions arising under the Securities Act or Exchange Act, please also ensure that the exclusive forum provision in the governing documents states this clearly.

Response:

In response to the Staff’s comment, the Company has revised its disclosure on page 59 of Amendment No. 1 and has revised the forum selection provision contained in its form of Second Amended and Restated Bylaws attached as Exhibit 3.2 to Amendment No. 1 to be consistent with that disclosure.

***

The Company hereby acknowledges 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 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.

We appreciate the Staff’s comments and request the Staff contact the undersigned at (561) 743-8333 or prawson@dyadic.com with any questions or comments regarding this letter.

Sincerely,

/s/Ping Rawson

Ping Rawson

Chief Accounting Officer

cc:

Mark Emalfarb (Dyadic International, Inc.)

Kimberly Petillo-Décossard (Cahill Gordon & Reindel LLP)

December 3, 2018
Ping Rawson
Chief Accounting Officer
Dyadic International, Inc.
140 Intracoastal Pointe Drive, Suite 404
Jupiter, Florida 33477
Re:Dyadic International, Inc.
Form 10-12G
Filed November 5, 2018
File No. 000-55264
Dear Mr. Rawson:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Registration Statement on Form 10-12(g) filed November 5, 2018
Other Market Opportunities, page 9
1.Please identify the parties with whom you have entered into the two funded proof of
concept research collaborations and file the agreements as exhibits.
Risks Related to the Potential Reverse Stock Split..., page 27
2.Please disclose the range of the reverse stock split ratios that your shareholders approved
and disclose any other material provisions of the stock split.
Item 13. Financial Statements and Supplementary Data, page 60
3.Please update the disclosures and financial statements in order to comply with Rule 8-08
of Regulation S-X.

 FirstName LastNamePing  Rawson
 Comapany NameDyadic International, Inc.
 December 3, 2018 Page 2
 FirstName LastName
Ping  Rawson
Dyadic International, Inc.
December 3, 2018
Page 2
General
4.Please be advised that your registration statement will automatically become effective 60
days after the initial filing date. Upon effectiveness, you will become subject to the
reporting requirements of the Securities Exchange Act of 1934, even if we have not
cleared comments. If you do not wish to incur those obligations until you have cleared
comments, you may wish to consider withdrawing your registration statement before it
becomes effective automatically and submitting a new registration statement when you
respond to our comments.
5.We note that your forum selection provision identifies the Court of Chancery of the State
of Delaware as the exclusive forum for certain litigation, including any “derivative
action.”  Please disclose whether this provision applies to actions arising under the
Securities Act or Exchange Act.  In that regard, we note that Section 27 of the Exchange
Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or
liability created by the Exchange Act or the rules and regulations thereunder. If this
provision does not apply to actions arising under the Securities Act or Exchange Act,
please also ensure that the exclusive forum provision in the governing documents states
this clearly.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Mindy Hooker (Staff Accountant) at 202-551-3728 or John
Cash (Accounting Branch Chief) at 202-551-3768 if you have questions regarding comments on
the financial statements and related matters.  Please contact Edward Kelly (Staff Attorney) at
202-551-3728 or Asia Timmons-Pierce (Special Counsel) at 202-551-3754 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction