SEC Comment Letter for GT Biopharma, Inc. (GTBP) (CIK 0000109657) (GTBP) — Jun 7, 2006
GT Biopharma, Inc. (GTBP) (CIK 0000109657)
Date: June 7, 2006 · CIK: 0000109657 · Accession: 0000000000-06-026612
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 6010 June 7, 2006 Michael D. Centron Chief Financial Officer OXIS International, Inc. 323 Vintage Park Drive, Suite B Foster City, CA 94404
Re: OXIS International, Inc. Schedule 14A Filed June 5, 2006 File No. 0-08092
Dear Mr. Centron:
We have limited our review of your filing to the issue we have addressed in our comment. Where indicated, we think you should revise your document in response to the comment. 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 necessary in your explanation.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements 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 free to call us at the telephone numbers listed at the end of this letter.
Proposal No. 2, page 13
1. Please disclose whether you currently have any plans to issue any of the shares that would be authorized through this proposal. If you do, please describe the plans and state how many shares will be issued pursuant to each such plan.
* * *
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 a marked copy of the amendment to expedite our review. Please furnish
Michael D. Centron OXIS International, Inc. June 7, 2006 Page 2 a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filing;
• 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Di vision of Corporation Finance in our review of your filing or in response to our comments on your filing.
Please contact Greg Belliston at (202) 551-3861 or me at (202) 551-3715 with any questions.
S i n c e r e l y ,
J e f f r e y R i e d l e r A s s i s t a n t D i r e c t o r
Show Raw Text
Mail Stop 6010
June 7, 2006
Michael D. Centron
Chief Financial Officer
OXIS International, Inc.
323 Vintage Park Drive, Suite B
Foster City, CA 94404
Re: OXIS International, Inc.
Schedule 14A
Filed June 5, 2006
File No. 0-08092
Dear Mr. Centron:
We have limited our review of your filing to the issue we have addressed in our
comment. Where indicated, we think you should revise your document in response to the comment. 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 necessary in your explanation.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements 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 free to call us at the telephone numbers listed at the end of this letter.
Proposal No. 2, page 13
1. Please disclose whether you currently have any plans to issue any of the shares that would be authorized through this proposal. If you do, please describe the plans and state how many shares will be issued pursuant to each such plan.
* * *
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 a marked copy of the amendment to expedite our review. Please furnish
Michael D. Centron
OXIS International, Inc. June 7, 2006 Page 2
a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filing;
• 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.
Please contact Greg Belliston at (202) 551-3861 or me at (202) 551-3715 with any questions.
S i n c e r e l y ,
J e f f r e y R i e d l e r
A s s i s t a n t D i r e c t o r