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SEC Company Response from AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504) (UAVS) — Sep 7, 2018

AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)
Date: Sept. 7, 2018 · CIK: 0000008504 · Accession: 0001575705-18-000193

AI Filing Summary & Sentiment

File numbers found in text: 333-226324

Referenced dates: September 5, 2018

Date
September 7, 2018
Author
/s/ Barrett
Form
CORRESP
Company
AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)

Letter

Office of Transportation and Leisure Securities and Exchange Commission AgEagle Aerial Systems Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed August 27, 2018 File No. 333-226324

Dear Mr. Dobbie:

On behalf of AgEagle Aerial Systems, Inc., a Nevada corporation (the “Company”), we hereby provide a response to the comments issued in a letter dated September 5, 2018 (the “Staff’s Letter”) regarding the Company’s Amendment No. 1 to Registration Statement on Form S-1 filed on August 27, 2018. Contemporaneously with this submission, we have filed an amendment to the Registration Statement on Form S-1 (the “Amended Form S-1”) reflecting the response of the Company below. To facilitate the review by the Commission’s staff (the “Staff”) of the Amended Form S-1, the Company hereby responds to the comment set forth in the Staff’s Letter. Certain capitalized terms set forth in this letter are used as defined in the Amended Form S-1.

Comment Number Comment and Response

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.

RESPONSE: As requested by the Staff, we have provided historical comparative unaudited interim financial statements for the six month period ended June 30, 2017.

Thank you very much for your time and attention in connection with this filing. Should you have any questions concerning any of the foregoing, please contact Tahra Wright, Esq., of Loeb & Loeb LLP, counsel to the Company, by telephone at (212) 407-4122.

Sincerely,
/s/ Barrett
Mooney

Show Raw Text
CORRESP
1
filename1.htm

AgEagle Aerial
Systems, Inc.

117 South 4th
Street

Neodesha, KS
66757

September 7, 2018

        Justin Dobbie

        Legal Branch Chief

        Office of Transportation and Leisure

        Securities and Exchange Commission

        100 F. Street, N.E.

        Washington, D.C. 20549

 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. Dobbie:

On behalf of AgEagle Aerial Systems,
Inc., a Nevada corporation (the “Company”), we hereby provide a response to the comments issued in a letter dated
September 5, 2018 (the “Staff’s Letter”) regarding the Company’s Amendment No. 1 to Registration Statement
on Form S-1 filed on August 27, 2018. Contemporaneously with this submission, we have filed an amendment to the Registration Statement
on Form S-1 (the “Amended Form S-1”) reflecting the response of the Company below. To facilitate the review by the
Commission’s staff (the “Staff”) of the Amended Form S-1, the Company hereby responds to the comment set forth
in the Staff’s Letter. Certain capitalized terms set forth in this letter are used as defined in the Amended Form S-1.

    Comment
    Number
    Comment and Response

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.

RESPONSE: As requested by the Staff,
we have provided historical comparative unaudited interim financial statements for the six month period ended June 30, 2017.

Thank you very much for your time and
attention in connection with this filing. Should you have any questions concerning any of the foregoing, please contact Tahra Wright,
Esq., of Loeb & Loeb LLP, counsel to the Company, by telephone at (212) 407-4122.

    Sincerely,

    /s/ Barrett
Mooney

    Barrett
Mooney, CEO