0001144204-18-018406.txt : 20180525 0001144204-18-018406.hdr.sgml : 20180525 20180402083625 ACCESSION NUMBER: 0001144204-18-018406 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180402 FILER: COMPANY DATA: COMPANY CONFORMED NAME: HUDSON TECHNOLOGIES INC /NY CENTRAL INDEX KEY: 0000925528 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-MACHINERY, EQUIPMENT & SUPPLIES [5080] IRS NUMBER: 133641539 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: PO BOX 1541 STREET 2: ONE BLUE HILL PLAZA, 14TH FLOOR CITY: PEARL RIVER STATE: NY ZIP: 10965 BUSINESS PHONE: 8457356000 MAIL ADDRESS: STREET 1: PO BOX 1541 STREET 2: ONE BLUE HILL PLAZA, 14TH FLOOR CITY: PEARL RIVER STATE: NY ZIP: 10965 FORMER COMPANY: FORMER CONFORMED NAME: REFRIGERANT RECLAMATION INDUSTRIES INC DATE OF NAME CHANGE: 19940617 CORRESP 1 filename1.htm

HUDSON TECHNOLOGIES, INC.

P.O. Box 1541

One Blue Hill Plaza

Pearl River, NY 10965

845-735-6000 (Phone)

 

April 2, 2018

 

VIA EDGAR

 

Ms. Pamela A. Long

Assistant Director

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 

Re: Hudson Technologies, Inc.
  Registration Statement on Form S-3
  Filed March 19, 2018
  File No. 333-223755

 

Dear Ms. Long:

 

We are in receipt of your letter dated March 27, 2018, which contained comments regarding our Registration Statement on Form S-3 filed on March 19, 2018. Listed below is a specific response to your numbered comment.

 

1.We note that Part III of your annual report on Form 10-K for the fiscal year ended December 31, 2017 incorporates by reference portions of your definitive proxy statement which has not been filed yet. Please be advised that we cannot accelerate the effective date of your registration statement until you have amended the Form 10-K to include Part III information or filed the definitive proxy statement. For guidance, please refer to Compliance and Disclosure Interpretations, Securities Act Forms Questions 123.01, available on the Commission’s website.

 

Response: In accordance with the staff’s comment, we will defer the acceleration of the effectiveness of the above-referenced registration statement until after we have amended the Form 10-K to include Part III information or filed the definitive proxy statement.

 

 

 

 

If you have any further questions regarding our response to your comments, please do not hesitate to call our counsel, Michael Grundei of Wiggin and Dana LLP, at 203-363-7630, or the undersigned at 845-735-6000.

 

 

  Sincerely,  
     
  /s/ Kevin J. Zugibe  
  Kevin J. Zugibe  
  Chairman and Chief Executive Officer  

 

 

cc: Nat Krishnamurti (Hudson Technologies, Inc.)
  Michael Grundei (Wiggin and Dana LLP)
  Sergio Chinos (Securities and Exchange Commission)

 

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