-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, MXIVidhIbZ3aBT0a35BSCJsuSJ2cSJlrggBFFYkP2WR8ocAOifPPVm1Uz3fB+v4c 1gD7S8p9LEG/BFojk5Klkg== 0000000000-05-039814.txt : 20060726 0000000000-05-039814.hdr.sgml : 20060726 20050802162437 ACCESSION NUMBER: 0000000000-05-039814 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050802 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: AROTECH CORP CENTRAL INDEX KEY: 0000916529 STANDARD INDUSTRIAL CLASSIFICATION: MISCELLANEOUS ELECTRICAL MACHINERY, EQUIPMENT & SUPPLIES [3690] IRS NUMBER: 954302784 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 632 BROADWAY STREET 2: STE 1200 CITY: NEW YORK STATE: NY ZIP: 10012 BUSINESS PHONE: 6466542107 MAIL ADDRESS: STREET 1: 632 BROADWAY STREET 2: SUITE 1200 CITY: NEW YORK STATE: NY ZIP: 10012 FORMER COMPANY: FORMER CONFORMED NAME: ELECTRIC FUEL CORP DATE OF NAME CHANGE: 19931223 LETTER 1 filename1.txt Mail Stop 6010 August 2, 2005 Leland Nall 354 Industry Drive Arotech Corporation Auburn, Alabama 36832 Re: Arotech Corporation Amendment No. 1 to Registration Statement on Form S-3 Filed July 20, 2005 File No. 333-124961 Draft of Amendment to Form 10-K for Fiscal Year Ended December 31, 2004 File No. 0-23336 Dear Mr. Nall: We have limited our review to selected portions of your registration statement, and we have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Amendment No. 1 to Registration Statement on Form S-3 Incorporation of Documents by Reference, page 24 1. Please update this section to the extent applicable. For example, this section should incorporate by reference your proxy filed June 7, 2005 and any additional amendments to the Form 10-K. Exhibits 2. Please refer to prior comment 2. As previously requested, please file the February 19, 2004 restated agreement mentioned in Exhibit 10.1. As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. You may contact Kristen Lochhead at (202) 551-3364 or Gary Todd at (202) 551-3605 if you have questions regarding comments on the financial statements and related matters. Please contact Tom Jones at (202) 551-3602 or me at (202) 551-3800 with any other questions. Sincerely, Peggy Fisher Assistant Director cc (via fax): Steven M. Skolnick, Esq. ?? ?? ?? ?? Leland Nall Arotech Corporation August 2, 2005 Page 2 -----END PRIVACY-ENHANCED MESSAGE-----