SEC Comment Letter for ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528) (OMEX) — Sep 26, 2018
ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528)
Date: Sept. 26, 2018 · CIK: 0000798528 · Accession: 0000000000-18-030326
AI Filing Summary & Sentiment
File numbers found in text: 001-31895
Letter
September 26, 2018 Jay A. Nudi Chief Financial Officer ODYSSEY MARINE EXPLORATION INC 5215 W. Laurel Street Tampa, Florida 33607 Re:Odyssey Marine Exploration Inc Form 10-K for the year ended December 31, 2017 Filed on March 26, 2018 File No. 001-31895 Dear Mr. Nudi: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the year ended December 31, 2017 Report of Independent Registered Public Accounting Firm, page 32 1.Please have your auditor's revise their audit report to comply with PCAOB AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion. Refer to SEC Release 34-81916.
FirstName LastNameJay A. Nudi Comapany NameODYSSEY MARINE EXPLORATION INC September 26, 2018 Page 2 FirstName LastName Jay A. Nudi ODYSSEY MARINE EXPLORATION INC September 26, 2018 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Effie Simpson at (202) 551-3346 or Claire Erlanger at (202) 551-3750 with any questions. Sincerely, Division of Corporation Finance Office of Transportation and Leisure
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September 26, 2018
Jay A. Nudi
Chief Financial Officer
ODYSSEY MARINE EXPLORATION INC
5215 W. Laurel Street
Tampa, Florida 33607
Re:Odyssey Marine Exploration Inc
Form 10-K for the year ended December 31, 2017
Filed on March 26, 2018
File No. 001-31895
Dear Mr. Nudi:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the year ended December 31, 2017
Report of Independent Registered Public Accounting Firm, page 32
1.Please have your auditor's revise their audit report to comply with PCAOB AS 3101, The
Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an
Unqualified Opinion. Refer to SEC Release 34-81916.
FirstName LastNameJay A. Nudi
Comapany NameODYSSEY MARINE EXPLORATION INC
September 26, 2018 Page 2
FirstName LastName
Jay A. Nudi
ODYSSEY MARINE EXPLORATION INC
September 26, 2018
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Effie Simpson at (202) 551-3346 or Claire Erlanger at (202) 551-3750
with any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure