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SEC Comment Letter for Anixa Biosciences Inc (ANIX) (CIK 0000715446) (ANIX) — Sep 10, 2015

Anixa Biosciences Inc (ANIX) (CIK 0000715446)
Date: Sept. 10, 2015 · CIK: 0000715446 · Accession: 0000000000-15-045125

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File numbers found in text: 333-206782

Date
September 10, 2015
Author
/s/ Mark P. Shuman
Form
UPLOAD
Company
Anixa Biosciences Inc (ANIX) (CIK 0000715446)

Letter

Mail Stop 4561 September 10, 2015 Robert A. Berman President and Chief Executive Officer ITUS Corporation 12100 Wilshire Boulevard, Suite 1275 Los Angeles, CA 90025

Re: ITUS Corporation Registration Statement on Form S-3 Filed September 4, 2015 File No. 333-206782

Dear Mr. Berman :

This is to advise you that we have not reviewed and will not review your registration statement .

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 the information the Securities Act of 193 3 and all applicable Securities Act rules require. 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 the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rule 461 regard ing requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the

Robert A. Berman ITUS Corporation September 10, 2015 Page 2

fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .

Please contact Ji Shin, Attorney -Advisor, at (202) 551 -3579, or me at (202) 551 -3462 with any questions.

Sincerely,
/s/ Mark P. Shuman

Show Raw Text
Mail Stop 4561
September 10, 2015

Robert A. Berman
President and Chief Executive Officer
ITUS Corporation
12100 Wilshire Boulevard, Suite 1275
Los Angeles, CA 90025

Re: ITUS Corporation
  Registration Statement on Form S-3
Filed  September 4, 2015
  File No.  333-206782

Dear Mr. Berman :

This is to advise you that we have not  reviewed and will not review your registration
statement .

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 the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   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 the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rule  461 regard ing requests for  acceleration .  We will consider a written
request for acceleration of the effective date of the registration statement as confirmation of the

Robert A. Berman
ITUS Corporation
September 10, 2015
Page 2

 fact that those requesting acceleration are aware of their respective responsibilities under the
Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please  contact Ji Shin, Attorney -Advisor, at (202) 551 -3579, or me at (202) 551 -3462
with any questions.

Sincerely,

 /s/ Mark P. Shuman

Mark P. Shuman
Branch Chief – Legal
Office of Information Technologies
and Services
cc: Barry I. Grossman, Esq.
Ellenoff Grossman & Schole LLP