5225
Katy Freeway, Suite 600
Houston,
Texas 77007
January
27, 2011
Jim B.
Rosenberg
Division
of Corporation Finance
United
States Securities and Exchange Commission
100 F.
Street NE
Washington,
D.C. 20549
Telephone
Number: (202) 551-3679
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Re:
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Spine
Pain Management, Inc.
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Form
10-K for the Fiscal Year Ended December 31, 2009
Filed
March 31, 2010
Form
10-Q for the Quarterly Period Ended June 30, 2010
Filed
August 16, 2010
File
No. 000-27407
Dear Mr.
Rosenberg,
On behalf
of Spine Pain Management, Inc. (the “Company,” “we” and “us”), set forth below
are the Company’s responses to the comments of the Staff of the Securities and
Exchange Commission (the “Staff”) to the Company’s Form 10-K for fiscal year
ended December 31, 2009, filed March 31, 2010, and the Company’s Form 10-Q for
the quarterly period ended June 30, 2010, filed August 16, 2010. The
Staff’s original comments were contained in the letter to the Company dated
September 21, 2010. The Company responded on September 29,
2010. The Staff sent a follow-up letter to the Company on November
24, 2010, which letter the Company responded to on December 8,
2010. The responses below relate specifically to the Staff’s second
follow-up letter to the Company dated January 21, 2011.
Form 10-K for Fiscal Year
Ended December 31, 2009
Item
7. Management’s Discussion and Analysis of Financial Condition and
Results of Operations
Critical Accounting
Policies
Page 1 of 2
Revenue Recognition, page
20
1. In
response to the Staff’s Comment 1 (referencing the Staff’s Comment 3 from its
November 24, 2010 letter), we will revise the presentation of our statements of
operations to omit “revenue” (i.e. gross revenue) and only include “net
revenue.” In connection with this revision to our presentation, we
will include a discussion in our notes to the financial statements and/or our
MD&A that explains our allowance for estimated discounts. We will
make this revision to our presentation in our Form 10-K for the year ended
December 31, 2010 and in all subsequent filings.
In
responding to the Staff’s comments, the Company acknowledges that:
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·
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the
Company is responsible for the adequacy and accuracy of the disclosure in
the filing;
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·
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Staff
comments or changes to disclosure in response to Staff comments do not
foreclose the Commission from taking any action with respect to the
filing; and
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·
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the
Company may not assert Staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
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If you
should need clarification or any additional information in connection with your
inquiries, please contact me. Thank you for your help in this
matter.
| Very truly yours, | |||
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/s/
William F. Donovan, M.D.
William F. Donovan, M.D.,
President
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