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VIA EDGAR
FILING
October 19, 2009
David R.
Humphrey
Branch
Chief
Securities
and Exchange Commission
100 F
Street N.E.
Washington,
D.C. 20549-3561
Re: Reading International,
Inc.
Form 10-K for the year ended December
31, 2008
Schedule 14A filed April 22,
2009
File No. 001-08625
Dear Mr.
Humphrey,
During
our review of our amended Annual Report on Form 10-K/A for year ended December
31, 2008, we noted an inconsistency in our roll up of the amount of stock
options and restricted stock noted in the reply letter we sent to you on October
13, 2009. As such, we are amending our reply letter for the
disclosure of the full amount of securities outstanding that are anti-dilutive
in accordance with ASC 260-10-50-1, paragraph c from 577,850, 577,850, and
514,100 to 915,470, 762,950, and 699,200 for the years ended December 31, 2008,
2007, and 2006, respectively. We intend to show this disclosure on
our amended 2008 Annual Report which we will file on October 20,
2009. Please see below the corrected response to your Question 1 of
your comment letter dated September 30, 2009.
Form
10-K
Notes to Consolidated
Financial Statements
Note 2 – Summary of
Significant Accounting Policies
Earnings per Share, page
64
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|
1.
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Please
explain to us why the numbers of shares excluded from the computation of
diluted loss per share shown here are different from the numbers of shares
shown in the last sentence of Note 4 on page
70.
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RESPONSE:
Note 2 on
page 64 states the following:
“We had
unissued restricted stock of 119,869 shares as of the year ended December 31,
2008 and stock options to purchase 577,850, 577,850, and 514,100 shares of Class
A Common Stock were outstanding at December 31, 2008, 2007, and 2006,
respectively, at a weighted average exercise price of $5.60, $5.60, and $5.21
per share, respectively. Stock options to purchase 185,100 shares of
Class B Common Stock were outstanding
at each of the years ended December 31, 2008, 2007, and 2006 at a weighted
average exercise price of $9.90 per share.”
Note 4 on
page 70 states the following:
“For the
years ended December 31, 2008 and 2007, we recorded losses from continuing
operations. As such, the incremental shares of 152,520 shares of
restricted Class A Non-Voting Common Stock and 233,760 of exercisable stock
options in 2008 and the 278,376 of exercisable stock options in 2007 were
excluded from the computation of diluted loss per share because they were
anti-dilutive in those periods.”
The
reference to 119,869 shares of unissued restricted stock indicated in Note 2 on
page 64 is incorrect. The correct number is as stated in Note 4 of
152,520 shares. In addition, we will disclose the full amount of
securities outstanding that are anti-dilutive in accordance with ASC
260-10-50-1, paragraph c of 915,470, 762,950, and 699,200 for the years ended
December 31, 2008, 2007, and 2006, respectively, in addition to the calculated
amount of incremental shares as was reported for the years ended December 31,
2008, 2007, and 2006, respectively. We will make these corrections in
our amended 2008 Form 10-K.
Please
feel free to contact me should you have any questions or require additional
information in connection with the above.
Sincerely,
/s/
Andrzej J. Matyczynski
Andrzej
J. Matyczynski
Chief
Financial Officer
Tel: 213
235 2238
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