SEC Comment Letter for AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504) (UAVS) — Apr 24, 2008
AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)
Date: April 24, 2008 · CIK: 0000008504 · Accession: 0000000000-08-021040
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 7010 April 24, 2008 Via U.S. Mail Mr. C. Stephen Cochennet President and Chief Executive Officer EnerJex Resources, Inc. 7300 W. 110 th, 7th Floor Overland Park, Kansas 66210
Re: EnerJex Resources, Inc. Schedule 14A Filed April 11, 2008 File No. 0-30234
Dear Mr. Cochennet: We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necess ary in your explanation. In some of our comments, we may ask you to pr ovide us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requir ements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel fr ee to call us at the telephone numbers listed at th e end of this letter.
Mr. C. Stephen Cochennet EnerJex Resources, Inc. April 24, 2008 page 2 of 3
Schedule 14A filed April 11, 2008
1. Please disclose, in a table or other similar format, the number of shares of your common stock that will be (i) issued and outstanding; (ii) authorized but out standing or reserved for issuance; and (iii) authorized but unissued after the comple tion of the reverse split.
2. We note that the reverse stock split will result in an increased number of authorized but unissued shares of your common stock. Do you have any current plans, proposals or arrangements, written or otherw ise to engage in any busine ss or investment opportunity? If so, please disclose and if not, please stat e that you have no such plans, proposals or arrangements written or otherwise at this time.
Closing Comments
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furn ish a cover letter with your amendment that keys your responses to our comments and pr ovides any requested information. Detailed cover lette rs greatly facilitate our review . Please understand that we may have additional comments afte r reviewing your amendment and responses to our comments. We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure in the filing to be certain that the filing includes all information re quired under the Securities Exchange Act of 1934 and that they have provi ded all information investors require for an informed investment decision. Since the compa ny and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of the disclosures they have made. In connection with responding to our comme nts, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
staff comments or changes to disclosure in re sponse to staff comments do not foreclose the Commission from taking any action with respect to the filing; and 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.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the sta ff of the Division of Corporati on Finance in our review of your filing or in response to our comments on your filing.
Mr. C. Stephen Cochennet EnerJex Resources, Inc. April 24, 2008 page 3 of 3 Please contact Carmen Moncada-Terry at (202) 551-3687 or in her absence, the undersigned (202) 551-3740 with any questions.
Sincerely,
H. Roger Schwall Assistant Director
cc: C. Moncada-Terry
Via Facsímile
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
April 24, 2008
Via U.S. Mail
Mr. C. Stephen Cochennet President and Chief Executive Officer EnerJex Resources, Inc. 7300 W. 110
th, 7th Floor
Overland Park, Kansas 66210
Re: EnerJex Resources, Inc. Schedule 14A
Filed April 11, 2008
File No. 0-30234
Dear Mr. Cochennet:
We have limited our review of your filing to those issues we have addressed in our
comments. Where indicated, we think you should revise your document in response to these
comments. If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Please be as detailed as necess ary in your explanation.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure. After reviewing th is information, we may raise additional
comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing. We look forward to working with you in these respects. We welcome any questions
you may have about our comments or any other aspect of our review. Feel fr ee to call us at the
telephone numbers listed at th e end of this letter.
Mr. C. Stephen Cochennet
EnerJex Resources, Inc.
April 24, 2008
page 2 of 3
Schedule 14A filed April 11, 2008
1. Please disclose, in a table or other similar format, the number of shares of your common
stock that will be (i) issued and outstanding; (ii) authorized but out standing or reserved
for issuance; and (iii) authorized but unissued after the comple tion of the reverse split.
2. We note that the reverse stock split will result in an increased number of authorized but
unissued shares of your common stock. Do you have any current plans, proposals or
arrangements, written or otherw ise to engage in any busine ss or investment opportunity?
If so, please disclose and if not, please stat e that you have no such plans, proposals or
arrangements written or otherwise at this time.
Closing Comments
As appropriate, please amend your filing and respond to these comments within 10
business days or tell us when you will provide us with a response. You may wish to provide us
with marked copies of the amendment to expedite our review. Please furn ish a cover letter with
your amendment that keys your responses to our comments and pr ovides any requested
information. Detailed cover lette rs greatly facilitate our review . Please understand that we may
have additional comments afte r reviewing your amendment and responses to our comments.
We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision. Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made. In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
staff comments or changes to disclosure in re sponse to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and
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.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
Mr. C. Stephen Cochennet
EnerJex Resources, Inc.
April 24, 2008
page 3 of 3
Please contact Carmen Moncada-Terry at (202) 551-3687 or in her absence, the
undersigned (202) 551-3740 with any questions.
Sincerely,
H. Roger Schwall Assistant Director
cc: C. Moncada-Terry
Via Facsímile
Jeffrey T. Haughey, Esq. 816-983-8080