United States securities and exchange commission logo
July 28, 2023
James Green
Chief Executive Officer
Harvard Bioscience, Inc.
84 October Hill Road
Holliston, MA 01746-1371
Re: Harvard Bioscience,
Inc.
Definitive Proxy
Statement on Schedule 14A
Filed April 5, 2023
File No. 001-33957
Dear James Green:
We have limited our review of your most recent definitive proxy
statement to those issues
we have addressed in our comments. Please respond to these comments by
confirming that you
will revise your future proxy disclosures in accordance with the topics
discussed below.
Definitive Proxy Statement on Schedule 14A filed April 5, 2023
Pay versus Performance, page 25
1. Refer to the pay versus
performance table. We note that the amounts listed for 2021 and
2022 in column (b) are
not the same as the amounts listed for those years in the PEO
"TOTAL" column of the
Summary Compensation Table on page 20. Similarly, the
average of the non-PEO
NEO amounts reported in column (d) do not appear to be
consistent with the
amounts reported in the "TOTAL" column of the Summary
Compensation Table for
the non-PEO NEOs. Please ensure that you have entered the
correct Summary
Compensation Table amounts in your pay versus performance tables
pursuant to Regulation
S-K Item 402(v) and that the calculation of compensation actually
paid and your
relationship disclosures reflect the appropriate calculations.
Please contact Cheryl Brown at 202-551-3905 or Amanda Ravitz at
202-551-3412 with
any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program