SEC Company Response from ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528) (OMEX) — Sep 27, 2018
ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528)
Date: Sept. 27, 2018 · CIK: 0000798528 · Accession: 0001193125-18-285827
AI Filing Summary & Sentiment
File numbers found in text: 001-31895
Letter
VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Corporation Finance Attention: Effie Simpson Odyssey Marine Exploration, Inc. (the “Company”) Form 10-K for the Year Ended December 31, 2017 (the “Form 10-K”) Filed March 26, 2018 SEC File No.: 001-31895
Dear Ms. Simpson:
The purpose of this letter is to respond to the Staff’s comment letter of September 26, 2018 (the “Comment Letter”), to the Company with respect to the above-referenced filing. Set forth below in bold are the comments from the Comment Letter, followed in each case by the Company’s response.
Form 10-K for the Year Ended December 31, 2017
Report of Independent Registered Public Accounting Firm, page 32
1. Please have your auditors 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.
Our auditors have revised their audit report to comply with PCAOB AS 3101. The Company will file a Form 10-K/A that includes the revised audit report.
*******
In connection with the Company’s response to the Comment Letter, the Company hereby acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
Securities and Exchange Commission
Page -2-
•
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.
Please feel free to contact me at (813) 314-2683 should you have any questions regarding this response.
Very truly yours,
ODYSSEY MARINE EXPLORATION, INC.
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CORRESP
5215 W. Laurel Street
Tampa, FL 33607
Tele: (813)876-1776
Fax: (813) 870-1921
September 27, 2018
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
Division of Corporation
Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Effie Simpson
Re:
Odyssey Marine Exploration, Inc. (the “Company”)
Form 10-K for the Year Ended December 31, 2017 (the
“Form 10-K”)
Filed March 26, 2018
SEC File No.: 001-31895
Dear Ms. Simpson:
The purpose of this letter is to respond to the Staff’s comment letter of September 26, 2018 (the “Comment
Letter”), to the Company with respect to the above-referenced filing. Set forth below in bold are the comments from the Comment Letter, followed in each case by the Company’s response.
Form 10-K for the Year Ended December 31, 2017
Report of Independent Registered Public Accounting Firm, page 32
1.
Please have your auditors 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.
Our auditors have revised their audit report to comply with PCAOB AS 3101. The Company will file a Form
10-K/A that includes the revised audit report.
*******
In connection with the Company’s response to the Comment Letter, the Company hereby acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
Securities and Exchange Commission
Page -2-
•
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.
Please feel free to contact me at (813) 314-2683 should you have any questions regarding this response.
Very truly yours,
ODYSSEY MARINE EXPLORATION, INC.
/s/ Jay A. Nudi
Jay A. Nudi
Chief Financial
Officer