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SEC Comment Letter for Anixa Biosciences Inc (ANIX) (CIK 0000715446) (ANIX) — Oct 23, 2017

Anixa Biosciences Inc (ANIX) (CIK 0000715446)
Date: Oct. 23, 2017 · CIK: 0000715446 · Accession: 0000000000-17-037450

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File numbers found in text: 333-220963

Date
October 23, 2017
Author
/s/ Jan Woo
Form
UPLOAD
Company
Anixa Biosciences Inc (ANIX) (CIK 0000715446)

Letter

Mail Stop 4561 October 23, 2017 Amit Kumar Chief Executive Officer ITUS Corporation 3150 Almaden Expressway, Suite 250 San Jose, CA 95118

Re: ITUS Corporation Registration Statement on Form S-3 Filed Octo ber 16, 2017 File No. 333-220963

Dear Dr. Kumar :

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.

Amit Kumar ITUS Corporation October 23, 2017 Page 2

Please refer to Rule s 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities u nder 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 Edwin Kim, Attor ney-Advisor, at (202) 551 -3297 or me at (202) 551 -3453 with any questions.

Sincerely,
/s/ Jan Woo

Show Raw Text
Mail Stop 4561

October 23, 2017

Amit Kumar
Chief Executive Officer
ITUS  Corporation
3150 Almaden Expressway, Suite 250
San Jose, CA 95118

Re: ITUS  Corporation
  Registration Statement on Form S-3
Filed  Octo ber 16, 2017
  File No.  333-220963

Dear Dr. Kumar :

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.

Amit Kumar
ITUS  Corporation
October 23, 2017
Page 2

 Please refer to Rule s 460 and  461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities u nder
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 Edwin Kim, Attor ney-Advisor,  at (202) 551 -3297 or me at (202) 551 -3453
with any questions.

Sincerely,

 /s/ Jan Woo

Jan Woo
Branch Chief -Legal
Office of Information Technologies
and Services

cc:  Matthew Bernstein , Esq.
Ellenoff Grossman & Schole LLP