SEC Comment Letter for AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504) (UAVS) — Sep 5, 2018
AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)
Date: Sept. 5, 2018 · CIK: 0000008504 · Accession: 0000000000-18-027499
AI Filing Summary & Sentiment
File numbers found in text: 333-226324
Letter
September 5, 2018 Barrett Mooney Chief Executive Officer AgEagle Aerial Systems Inc. 117 South 4th Street Neodesha, KS 66757 Re:AgEagle Aerial Systems Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed August 27, 2018 File No. 333-226324 Dear Mr. Mooney: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 3, 2018 letter. Amendment No. 1 to Registration Statement on Form S-1 General 1.We note your response to our prior comment 1 and that the Agribotix historical and pro forma financial statements are included within the filing. In that regard, please also provide historical comparative unaudited interim financial statements for the six month period ended June 30, 2017.
FirstName LastNameBarrett Mooney Comapany NameAgEagle Aerial Systems Inc. September 5, 2018 Page 2 FirstName LastName Barrett Mooney AgEagle Aerial Systems Inc. September 5, 2018 Page 2 Please contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie, Legal Branch Chief, at 202-551-3469 with any questions. Sincerely, Division of Corporation Finance Office of Transportation and Leisure
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September 5, 2018
Barrett Mooney
Chief Executive Officer
AgEagle Aerial Systems Inc.
117 South 4th Street
Neodesha, KS 66757
Re:AgEagle Aerial Systems Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed August 27, 2018
File No. 333-226324
Dear Mr. Mooney:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our August 3, 2018 letter.
Amendment No. 1 to Registration Statement on Form S-1
General
1.We note your response to our prior comment 1 and that the Agribotix historical and pro
forma financial statements are included within the filing. In that regard, please also
provide historical comparative unaudited interim financial statements for the six month
period ended June 30, 2017.
FirstName LastNameBarrett Mooney
Comapany NameAgEagle Aerial Systems Inc.
September 5, 2018 Page 2
FirstName LastName
Barrett Mooney
AgEagle Aerial Systems Inc.
September 5, 2018
Page 2
Please contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie, Legal Branch
Chief, at 202-551-3469 with any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure