![]() | Tel 503 243 2300 Fax 503 241 8014 | Holland & Knight LLP 2300 US Bancorp Tower 111 S.W. Fifth Avenue Portland, OR 97204 www.hklaw.com | ||
January 23, 2008 | ||||
Mark A. von Bergen | ||||
(503) 243 5874 | ||||
FILED VIA EDGAR | mark.vonbergen@hklaw.com |
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 7010
Washington, D.C. 20549
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 7010
Washington, D.C. 20549
Attn: John Stickel, Attorney
Re: | Converted Organics Inc. | |||
Post-Effective Amendment No. 2 to Form SB-2 | ||||
Filed January 15, 2008 | ||||
SEC File No. 333-135174 |
Dear Mr. Stickel:
On behalf of Converted Organics Inc., a Delaware corporation (the “Company”), we submit the following response to the Division’s letter of January 23, 2008 regarding Post-Effective Amendment No. 2 to Form SB-2. For your convenience, we have reproduced the comment from your letter and our response follows the comment.
General
1. | We note that you have not previously amended theForm SB-2 to update the financial statements, since its effective date of February 12, 2007. Please provide us a letter confirming that you have not sold securities under theForm SB-2 during any periods when current financial statements would have been required pursuant to Section 10(a)(3) of the Securities Act of 1933. |
This letter confirms that the Company has not sold securities under the Form SB-2 during any periods when current financial statements would have been required pursuant to Section 10(a)(3) of the Securities Act of 1933.
Very truly yours, HOLLAND & KNIGHT LLP Submitted via Edgar Mark A. von Bergen | ||||
cc: | Edward J. Gildea, Converted Organics |
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