EDAC Technologies Corporation
1806 New Britain Ave.
Farmington, CT 06032
860-677-2603
Fax 860-674-2718
November 18, 2011
Mr. Max A. Webb
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, DC 20549
Re: Letter dated October 26, 2011
EDAC Technologies Corporation File No. 001-33507
Form 10-K for the year ended January 1, 2011
Dear Mr. Webb:
The following is the response of EDAC Technologies Corporation (the “Company”) to the comment in the Securities and Exchange Commission (“SEC”) Staff’s comment letter dated October 26, 2011 (the “Comment Letter,” relating to the Company’s Form 10-K for the year ended January 1, 2011 (the “Form 10-K”). The numbered response below corresponds to the numbered paragraph in the Comment Letter.
1. In future filings, we will expand the discussion of Short-Term Incentives in the Compensation Discussion and Analysis of the Definitive Proxy Statement, to quantify all company-wide performance targets. In addition, the Company’s targets for the fiscal year ended December 31, 2011, are not expected to be materially different from those of January 1, 2011.
The Company acknowledges the following with the Commission:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in the filings; |
| • | 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 |
| • | 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. |
Sincerely,
/s/Glenn L. Purple
Glenn L. Purple
Vice President-Finance
