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SEC Company Response from GT Biopharma, Inc. (GTBP) (CIK 0000109657) (GTBP) — Feb 9, 2007

GT Biopharma, Inc. (GTBP) (CIK 0000109657)
Date: Feb. 9, 2007 · CIK: 0000109657 · Accession: 0001144204-07-006095

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File numbers found in text: 333-139216

Referenced dates: December 19, 2006

Date
Feb. 9, 2007
Author
Edgar D. Park, Esq.
Form
CORRESP
Company
GT Biopharma, Inc. (GTBP) (CIK 0000109657)

Letter

Securities and Exchange Commission Division of Corporation Finance Re: OXIS International, Inc. Form SB-2 Registration Statement filed December 8, (File No. 333-139216)

Dear Ms. Fraser:

On behalf of OXIS International, Inc. (the “Company”), I write in reference to the above registration statement filed on December 8, 2006, in addition to the comments received from the staff (“Staff”) of the Securities and Exchange Commission in a letter dated December 19, 2006, and our response letter and Amendment No. 1 filed on January 10, 2007, and our response letter and Amendment No. 2 filed on January 23, 2007, amending the above referenced registration statement. References in this letter to “we,” “our,” or “us” mean the Company or its advisors, as the context may require.

In a series of telephone conversations from January 12, 2007 through February 8, 2007, the Staff requested that we revise the executive compensation data in the registration statement to comply with the recent changes to rules regarding executive compensation and related person disclosure for small business issuers. In response to this request, the Company has further amended its registration statement to include a revised summary compensation table, the outstanding equity awards at fiscal year-end table, and the director compensation table. These revisions appear on pages 65, 66, 67 and 68 of Amendment No. 3 to the registration statement filed today (February 9, 2007).

If you have any questions, please contact me by telephone at (310) 208-1182, or by facsimile at (310) 208-1154.

Very
truly yours,
/s/
Edgar D. Park, Esq.

Show Raw Text
CORRESP
1
filename1.htm

    RICHARDSON
      & PATEL LLP

    10900
      Wilshire Boulevard, Suite 500

    Los
      Angeles, California 90024-6525

    Telephone
      (310) 208-1182

    Telecopier
      (310) 208-1154

    February
      9, 2007

    Filed
      as Correspondence Via EDGAR

    Securities
      and Exchange Commission

    Division
      of Corporation Finance

    100
      F.
      Street, N.E.

    Washington,
      D.C. 20549-6010

    Attn:
      Mary K. Fraser, Esq.

              Re:

                OXIS
                  International, Inc.

                  Form
                    SB-2 Registration Statement filed December 8,
                    2006

                  (File
                    No.
                    333-139216)

    Dear
      Ms.
      Fraser:

    On
      behalf
      of OXIS International, Inc. (the “Company”), I write in reference to the above
      registration statement filed on December 8, 2006, in addition to the comments
      received from the staff (“Staff”) of the Securities and Exchange Commission in a
      letter dated December 19, 2006, and our response letter and Amendment No. 1
      filed on January 10, 2007, and our response letter and Amendment No. 2 filed
      on
      January 23, 2007, amending the above referenced registration statement.
      References in this letter to “we,” “our,” or “us” mean the Company or its
      advisors, as the context may require.

    In
      a
      series of telephone conversations from January 12, 2007 through February 8,
      2007, the Staff requested that we revise the executive compensation data in
      the
      registration statement to comply with the recent changes to rules regarding
      executive compensation and related person disclosure for small business issuers.
      In response to this request, the Company has further amended its registration
      statement to include a revised summary compensation table, the outstanding
      equity awards at fiscal year-end table, and the director compensation table.
      These revisions appear on pages 65, 66, 67 and 68 of Amendment No. 3 to the
      registration statement filed today (February 9, 2007).

    If
      you
      have any questions, please contact me by telephone at (310) 208-1182, or by
      facsimile at (310) 208-1154.

              Very
                truly yours,

              /s/
                Edgar D. Park, Esq.

            cc:

              Marvin
                S. Hausman, MD

    OXIS
      International, Inc.