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SEC Company Response from Anixa Biosciences Inc (ANIX) (CIK 0000715446) (ANIX) — Jun 16, 2014

Anixa Biosciences Inc (ANIX) (CIK 0000715446)
Date: June 16, 2014 · CIK: 0000715446 · Accession: 0001513162-14-000389

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File numbers found in text: 000-11254

Referenced dates: June 12, 2014

Date
June 16, 2014
Author
Robert A. Berman
Form
CORRESP
Company
Anixa Biosciences Inc (ANIX) (CIK 0000715446)

Letter

Via EDGAR Ji Kim Attorney - Adviser United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NW Washington, DC 20549 CopyTele, Inc. Preliminary Proxy Statement on Schedule 14A Filed on June 3, 2014 File No. 000-11254

Re:

Dear Ms. Kim:

CopyTele, Inc. (“CopyTele”, the “Company”, “we”, “us” or “our”) hereby transmits its response to the letter received by us from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated June 12, 2014 regarding our Preliminary Proxy Statement on Schedule 14A (the “Preliminary Proxy Statement”) previously filed on June 3, 2014. For your convenience, we have repeated below the Staff’s comment in bold and have followed such comment with the Company’s response.

Proposal 4

1. Please tell us, and expand your disclosure to reference, what in your bylaws, articles of incorporation or other governing documents permits you to change your corporate name to another name to be selected by you at a later date without informing shareholders of the new name. In your response letter, explain how the authority the board seeks with respect to a future selection of a corporate name is consistent with Delaware law and the proxy rules.

In light of the comment we have revised our Preliminary Proxy Statement to include the new name that our board of directors selected.

******************

In making this response the Company acknowledges 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.

We thank the Staff in advance for its consideration of the enclosed and the foregoing responses. Should you have any questions concerning the foregoing responses, please contact Matthew Bernstein, Esq. at (212) 370-1300.

Very truly yours,
COPYTELE, INC.

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CORRESP
1
filename1.htm

CORRESP

 June 16, 2014

 Via EDGAR
Ji Kim
Attorney - Adviser
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NW
Washington, DC 20549

  Re:

 CopyTele, Inc.

              Preliminary Proxy Statement on Schedule 14A

              Filed on June 3, 2014

              File No. 000-11254

 Dear Ms. Kim:

 CopyTele, Inc. (“CopyTele”, the “Company”, “we”, “us” or “our”) hereby transmits its response to the letter received by us from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated June 12, 2014 regarding our Preliminary Proxy Statement on Schedule 14A (the “Preliminary Proxy Statement”) previously filed on June 3, 2014. For your convenience, we have repeated below the Staff’s comment in bold and have followed such comment with the Company’s response.

 Proposal 4

 1. Please tell us, and expand your disclosure to reference, what in your bylaws, articles of incorporation or other governing documents permits you to change your corporate name to another name to be selected by you at a later date without informing shareholders of the new name. In your response letter, explain how the authority the board seeks with respect to a future selection of a corporate name is consistent with Delaware law and the proxy rules.

 In light of the comment we have revised our Preliminary Proxy Statement to include the new name that our board of directors selected.

 ******************

 In making this response the Company acknowledges 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.

 We thank the Staff in advance for its consideration of the enclosed and the foregoing responses.  Should you have any questions concerning the foregoing responses, please contact Matthew Bernstein, Esq. at (212) 370-1300.

 Very truly yours,

 COPYTELE, INC.

 By: /s/ Robert A. Berman
Name: Robert A. Berman
Title: President and Chief Executive Officer