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SEC Company Response from AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504) (UAVS) — Oct 20, 2014

AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)
Date: Oct. 20, 2014 · CIK: 0000008504 · Accession: 0001144204-14-062008

AI Filing Summary & Sentiment

File numbers found in text: 333-198949

Referenced dates: October 9, 2014

Date
October 20, 2014
Author
/s/ Douglas M. Wright
Form
CORRESP
Company
AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)

Letter

Securities and Exchange Commission Attention: H. Roger Schwall Registration Statement on Form S-1 Filed September 25, 2014 File No. 333-198949

Re: EnerJex Resources, Inc.

Dear Mr. Schwall

In response to your letter dated October 9, 2014, set forth below are your comments concerning the EnerJex Resources, Inc.'s Registration Statement on Form S-1 referred to above, and our responses. Your comments are in italics and are followed by our response.

Registration Statement on Form S-1

General

1. Please revise your filing to provide the information about the interests of named experts and counsel required by Item 509 of Regulation S-K with regard to Michael E. Pfau and the Pfau Revocable Trust of 2003.

EnerJex response:

We have revised the Registration Statement to provide the requested information about Michael E. Pfau and the Pfau Revocable Trust of 2003. Please see pages 33, 36, and 39.

Index to Exhibits, page II-5

2. Please provide as Exhibit 5.1 the legality opinion required by Item 601(b)(5) of

Regulation S-K.

EnerJex response:

We have revised the Registration Statement to provide the required legality opinion. Please see Exhibit 5.1.

We hereby acknowledge that:

· the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

4040 Broadway, Suite 508 | San Antonio, TX 78209 | 210-451-5545 (P) | 210-463-9297 (F)

· staff comments or changes to disclosure in response 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.

If you have any questions or would like to discuss our responses above, you may contact our outside counsel, Fernando Velez, Jr. of Reicker, Pfau, Pyle & McRoy, LLP, at 805-966-2440, or me at 210-451-5545.

Very truly yours,
/s/ Douglas M. Wright

Show Raw Text
CORRESP
1
filename1.htm

October 20, 2014

Securities and Exchange Commission

Judiciary Plaza

450 Fifth Street, NW

Washington, DC 20549

Attention: H. Roger Schwall

    Re:
    EnerJex Resources, Inc.

    Registration Statement on Form S-1

    Filed September 25, 2014

    File No. 333-198949

Dear Mr. Schwall

In response to your letter
dated October 9, 2014, set forth below are your comments concerning the EnerJex Resources, Inc.'s Registration Statement on Form
S-1 referred to above, and our responses. Your comments are in italics and are followed by our response.

Registration Statement on Form S-1

General

1.
Please revise your filing to provide the information about the interests of named experts and counsel required by Item 509
of Regulation S-K with regard to Michael E. Pfau and the Pfau Revocable Trust of 2003.

EnerJex response:

We have revised the Registration Statement
to provide the requested information about Michael E. Pfau and the Pfau Revocable Trust of 2003. Please see pages 33, 36, and 39.

Index to Exhibits, page II-5

2.
Please provide as Exhibit 5.1 the legality opinion required by Item 601(b)(5) of

Regulation S-K.

EnerJex response:

We have revised the Registration Statement
to provide the required legality opinion. Please see Exhibit 5.1.

We hereby acknowledge that:

 · the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

4040 Broadway, Suite 508 | San Antonio,
TX 78209 | 210-451-5545 (P) | 210-463-9297 (F)

 · staff comments or changes to disclosure in response 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.

If you have any questions or would like
to discuss our responses above, you may contact our outside counsel, Fernando Velez, Jr. of Reicker, Pfau, Pyle & McRoy, LLP,
at 805-966-2440, or me at 210-451-5545.

Very truly yours,

/s/ Douglas M. Wright

Douglas M. Wright

Chief Financial Officer

 cc: Fernando Velez – via email

4040 Broadway, Suite 508 | San Antonio,
TX 78209 | 210-451-5545 (P) | 210-463-9297 (F)