DYNACQ HEALTHCARE, INC.
4301 VISTA ROAD, PASADENA, TEXAS 77504
October 4, 2012
BY EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-4628
Attn: Jeffrey Riedler, Assistant Director
| Re: | Dynacq Healthcare, Inc. |
Amendment No. 1 to Information Statement on Schedule 14C
Filed October 3, 2012
File No. 000-21574
Ladies and Gentlemen:
On October 3, 2012, Dynacq Healthcare, Inc. (the “Company”) filed Amendment No. 1 to a Preliminary Information Statement on Schedule 14C (the “Information Statement”). By letter dated October 4, 2012, the Company has received the comment of the staff of the Division of Corporation Finance (the “Staff”) relating to the Information Statement (the “Comment Letter”).
The following repeats the comment in the Comment Letter for your convenience, followed by the Company’s response to the comment.
| 1. | We note your response to our prior comment 1. In regard to the removal of Ping S. Chu, James G. Gerace and Stephen L. Huber from their positions as members of your Board of Directors, please confirm that you will file an Item 5.02 Form 8-K and, as applicable, follow the procedures outlined in Item 5.02(a)(2) and (3). |
Response: In response to the Staff’s comment, the Company hereby confirms that it will file an Item 5.02 Form 8-K and, if applicable, follow the procedures outlined in Item 5.02(a)(2) and (3).
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Securities and Exchange Commission
October 4, 2012
Page 2
If any member of the Staff has any questions concerning these matters or needs additional information or clarification, he or she should contact the undersigned at (713) 378-2000 or Brian P. Fenske at (713) 651-5557 or Davor Vukadin at (713) 651-5238, each of Fulbright & Jaworski L.L.P., counsel to the Company.
| Very truly yours, | ||
| DYNACQ HEALTHCARE, INC. | ||
| By: | /s/ Dr. Eric K. Chan | |
| Dr. Eric K. Chan | ||
| Chief Executive Officer and President | ||
DV/jy
| cc: | Johnny Gharib (Securities and Exchange Commission) | |
| Daniel Greenspan (Securities and Exchange Commission) | ||
| Brian P. Fenske (Fulbright & Jaworski L.L.P.) | ||
| Davor Vukadin (Fulbright & Jaworski L.L.P.) |
