[Letterhead of Dynamic Materials Corporation]
September 24, 2009
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attn: Mr. John Cash, Branch Chief
Re: | Dynamic Materials Corporation |
| Form 10-K for the year ended December 31, 2008 |
| Definitive Proxy Statement, filed April 24, 2009 |
| Form 10-Q for the quarter ended March 31, 2009 |
| Form 10-Q for the quarter ended June 30, 2009 |
| File No. 1-14775 |
Dear Mr. Cash:
Dynamic Materials Corporation, a Delaware corporation (the “Company”), hereby responds to the comments received by the Company from the staff of the Securities and Exchange Commission (the “Commission”) set forth in its letter, dated September 17, 2009 (the “Comment Letter”) with respect to the above referenced reports and other filings of the Company. For your convenience, we have restated the comment from the Comment Letter below, followed by the Company’s response.
Form 10-K for the Fiscal Year Ended December 31, 2008
Exhibit 10.1 - Credit Agreement Dated November 16, 2007
1. Comment: We note your response to comment 4 in our letter dated August 25, 2009 and we have reviewed the credit agreement filed as Exhibit 10.2 to Form 8-K/A, which was filed on September 11, 2009. Please note that Item 601(b)(2) of Regulation S-K does not apply to exhibits filed under Item 601(b)(10) of Regulation S-K and that Item 601(b)(10) does not contain a materiality threshold. Please file the omitted schedules and exhibits in your next Exchange Act filing.
Response: We will file the complete credit agreement with all schedules and exhibits, including those previously omitted, as an exhibit to our Form 10-Q for the quarter ending September 30, 2009.
If you would like to discuss any of the responses above or any other matter, please contact the undersigned at (303) 604-3938 or our outside securities counsel, Garth Jensen of Holme Roberts & Owen, at (303) 866-0368.
Sincerely,
/s/ Richard A. Santa |
|
Richard A. Santa
Senior Vice President, Chief Financial Officer
and Secretary
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