RadNet, Inc.
1510 Cotner Avenue
Los Angeles, CA 90025
April 30, 2007
VIA EDGAR AND FEDEX
Ms. Raquel Howard
Staff Accountant
U.S. Securities and Exchange Commission
Mail Stop 3561
100 F. Street, N.E.
Washington, D.C. 20549
Re: RadNet, Inc. - Item 4.01 Form 8-K Filed on April 17, 2007
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(File No. 001-33307)
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Dear Ms. Howard:
We are responding to the comments in your letter to RadNet, Inc., dated
April 23, 2007, concerning our Form 8-K referred to above.
Set forth below are our responses to the Staff's comments. For your
convenience, we have included each of the Comments in italicized text before the
corresponding response.
RESPONSES:
1. WE NOTE YOUR DISCLOSURE THAT MOSS ADAMS LLP DECLINED TO STAND FOR
RE-ELECTION AS YOUR INDEPENDENT ACCOUNTANT. PLEASE CONFIRM THAT YOUR
AUDIT/CLIENT RELATIONSHIP WITH THEM HAS ENDED AND THE DATE. IF THIS IS
TRUE, PLEASE REVISE YOUR DISCLOSURE ACCORDINGLY OR ADVISE. SEE ITEM 304
OF REGULATION S-B.
We respectfully submit to you that our audit/client relationship with
Moss Adams LLP has not yet ended as of the date of this letter.
Although Moss Adams LLP has notified us that they do not intend to
stand for reelection, they have agreed to continue to work with us
through the filing of our next Quarterly Report on Form 10-Q.
Ms. Howard
April 30, 2007
Page 2
2. WE NOTE YOU FILED INFORMATION REGARDING NON-RELIANCE ON PREVIOUSLY
ISSUED FINANCIAL STATEMENTS UNDER ITEM 4.01 FORM 8-K RATHER THAN AN
ITEM 4.02. PLEASE AMEND YOUR FILING TO INCLUDE ITEM 4.02 NON-RELIANCE
ON PREVIOUSLY ISSUED FINANCIAL STATEMENTS OR A RELATED AUDIT REPORT OR
COMPLETED INTERIM REVIEW AND REQUIRED DISCLOSURES.
We respectfully submit to you that we have previously included in our
Form 10-K filed on February 7, 2007 for the fiscal year ended October
31, 2006 and in our Form 10-K/T filed on April 17, 2007 disclosure
pertaining to our non-reliance on previously issued financial
statements. We have also amended our filing to include Item 4.02 of
Form 8-K to reflect our disclosures contained in the Forms 10-K,
referred to above, regarding non-reliance on previously issued
financial statements.
3. PLEASE AMEND YOUR FILING TO DISCLOSE THE DATE YOU CONCLUDED THAT YOUR
FINANCIAL STATEMENTS SHOULD NO LONGER BE RELIED ON.
In connection with the preparation of our Form 10-K, referred to above,
we concluded on February 2, 2007 that our financial statements should
no longer be relied upon. We have amended our filing to reflect that
information. We have also previously disclosed that in our Form 10-K
and Form 10-K/T filings.
4. PLEASE REVISE YOUR DISCLOSURE TO STATE WHETHER YOUR AUDIT COMMITTEE, OR
BOARD OF DIRECTORS, OR AUTHORIZED OFFICERS DISCUSSED WITH YOUR
INDEPENDENT ACCOUNTANT THE MATTERS DISCLOSED IN THE FILING. REFER TO
ITEM 4.02 OF FORM 8-K INSTRUCTIONS.
We confirm that our audit committee discussed with our independent
accountant the matters disclosed in the filing. We have revised our
disclosure to reflect that discussion.
In connection with this response, we hereby acknowledge that:
o The company is responsible for the adequacy and accuracy of
the disclosure in the filings;
o Staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose
the Commission from taking any action with respect to the
filing; and
o 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.
Ms. Howard
April 30, 2007
Page 3
If you have any questions, please contact me at (310) 478-7808.
Very truly yours,
/s/ Dr. Howard G. Berger
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Dr. Howard G. Berger
Chief Executive Officer
cc: Dr. David Swartz, Audit Committee Chairman, RadNet, Inc.
Jeff Linden, General Counsel
Linda Michaelson