Krage & Janvey, L.L.P.
Attorneys and Counselors at Law
2100 Ross Avenue
Suite 2600
Dallas, TExas 75201
Telephone 214/969-7500
FACSIMILE 214/220-0230
February 28, 2008
VIA FAX TO 202-772-9218
Mr. David Burton
Staff Accountant
United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: | Retractable Technologies, Inc. |
| Form 10-K for the Year Ended December 31, 2006 |
| Filed April 2, 2007 |
| File No. 1-16465 |
Dear Mr. Burton:
The purpose of this letter is to inform you, on behalf of Retractable Technologies, Inc. (the “Company”), that it filed a Form 10-K/A on Wednesday, February 27, 2008. This filing was submitted at your direction primarily: 1) to amend Item 9A. Controls and Procedures to provide greater detail regarding the disclosed material weakness discovered regarding the initial booking of a significant entry in the wrong period and 2) to amend Exhibit No. 31.2 to re-insert the introductory language to paragraph 4 which was inadvertently deleted from the certification. The Form 10-K was also amended where necessary to reflect material events that have occurred subsequent to April 2, 2007, including, but not limited to, the conclusion of the 2007 fiscal year, the termination of a lease from an affiliate, changes in key employees, subsequent litigation filed by us against Becton, Dickinson & Company (“BD”) and by BD and MDC Investment Holdings, Inc. against us, our annual meeting, the resignation of an independent Director, and the appointment of an independent Director.
Very truly yours, |
|
/s/ Ralph S. Janvey |
|
Ralph S. Janvey |
