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SEC Comment Letter for CIRTRAN CORP (CIRX) (CIK 0000813716) (CIRX) — Jun 5, 2018

CIRTRAN CORP (CIRX) (CIK 0000813716)
Date: June 5, 2018 · CIK: 0000813716 · Accession: 0000000000-18-017233

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
June 4, 2018
Author
/s/ Pamela Howell
Form
UPLOAD
Company
CIRTRAN CORP (CIRX) (CIK 0000813716)

Letter

Mail Stop 3561 June 4, 2018 Via E -mail Iehab J. Hawatmeh Chief Executive Officer CirTran Corporation 4125 South 6000 West West Valley City, Utah 84128

Re: CirTran Corporation Form 10-12G Filed May 11, 2018 File No. 000 -49654

Dear Mr. Hawatmeh:

We have reviewed your filing 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 r esponse.

After reviewing your response and any amendment you may file in response to these comments, we may have additional comments.

Directors and Executive Officers, page 16

1. Please briefly discuss the specific experience, qualification s, attributes or skills that led to the conclusion that each director should serve as a director for the company in light of the company’s business and structure, as required by Item 401(e)(1) of Regulation S -K.

Summary Compensation Table, page 17

2. Please revise the table to include the amount that Mr. Hawatmeh earned in 2017 as salary and bonus but that has been accrued, as required by Item 402(n)(2)(iii) of Regulation S-K. See Instruction 4 to Item 402(n).

Iehab J. Hawatmeh CirTran Corporation June 4, 2018 Page 2

Item 15. Financial Statements and Exhibi ts, page 24

3. Please update your financial statements to include the interim financial statements for the period ended March 31, 2018. See Rule 8 -08 of Regulation S -X.

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 Brian McAllister at (202) 551 -3341 or Angela Lumley at (202) 551 - 3398 if you have questions regarding comments on the financ ial statements and related matters. Please contact Ronald (Ron) E. Alper at (202) 551 -3329 or Pam Howell at (202) 551 -3357 with any other questions.

Sincerely,
/s/ Pamela Howell
for

Show Raw Text
Mail Stop 3561

June 4, 2018

Via E -mail
Iehab J. Hawatmeh
Chief Executive Officer
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re: CirTran Corporation
 Form 10-12G
Filed May 11, 2018
File No. 000 -49654

Dear Mr. Hawatmeh:

We have reviewed your filing 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 r esponse.

After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.

Directors and Executive Officers, page 16

1. Please briefly discuss the specific experience, qualification s, attributes or skills that led to
the conclusion that each director should serve as a director for the company in light of the
company’s business and structure, as required by Item 401(e)(1) of Regulation S -K.

Summary Compensation Table, page 17

2. Please  revise the table to include the amount that Mr. Hawatmeh earned in 2017 as salary
and bonus but that has been accrued, as required by Item 402(n)(2)(iii) of Regulation
S-K.  See Instruction 4 to Item 402(n).

Iehab J. Hawatmeh
CirTran Corporation
June 4, 2018
Page 2

 Item 15. Financial Statements and Exhibi ts, page 24

3. Please update your financial statements to include the interim financial statements for the
period ended March 31, 2018.  See Rule 8 -08 of Regulation S -X.

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 Brian McAllister at (202) 551 -3341 or Angela Lumley at (202) 551 -
3398 if you have questions regarding comments on the financ ial statements and related matters.
Please contact Ronald (Ron) E. Alper at (202) 551 -3329 or Pam Howell  at (202) 551 -3357  with
any other questions.

Sincerely,

 /s/ Pamela Howell
 for

 John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc: James R. Kruse, Esq.
      Michael Best & Friedrich, LLP