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SEC Company Response from GeoVax Labs, Inc. (GOVX) (CIK 0000832489) (GOVX) — Jun 25, 2010

GeoVax Labs, Inc. (GOVX) (CIK 0000832489)
Date: June 25, 2010 · CIK: 0000832489 · Accession: 0000950123-10-061113

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File numbers found in text: 333-165828

Date
June 24, 2010
Author
Assistant Director
Form
CORRESP
Company
GeoVax Labs, Inc. (GOVX) (CIK 0000832489)

Letter

United States Securities and Exchange Commission Division of Corporation Finance RE: GeoVax Labs, Inc. Registration Statement on Form S-1 File No. 333-165828

Dear Mr. Riedler:

In accordance with Rule 461, I am writing this letter on behalf of GeoVax Labs, Inc., the registrant, to request that the Securities and Exchange Commission declare the above-captioned registration statement effective at 5:00 p.m., June 28, 2010, or as soon as practicable thereafter.

GeoVax Labs, Inc. (the “Company”) hereby acknowledges that:

•

it is aware of its obligations under the Securities Act of 1933;

•

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 with 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 the 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.

Mr. Jeffrey P. Riedler

June 24, 2010

Page 2

If you have any questions, please contact me at 678-384-7224. Thank you for your time and attention.

Very truly yours,

GEOVAX LABS, INC.

By: /s/ Mark W. Reynolds

Mark W. Reynolds

Chief Financial Officer

cc:

Nandini Acharya, Esq.

Robert T. McNally, Ph.D.

Clinton D. Richardson, Esq.

T. Clark Fitzgerald III, Esq.

GLOBAL HUNTER SECURITIES LLC

400 Poydras Street, Suite 1510

New Orleans, Louisiana 70130

(504) 410-8010

June 24, 2010

Mr. Jeffrey P. Riedler

Assistant Director

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

RE:

GeoVax Labs, Inc.

Registration Statement on Form S-1

File No. 333-165828

Dear Mr. Riedler:

In accordance with Rule 461, I am writing this letter on behalf of Global Hunter Securities LLC, placement agent (the “Placement Agent”) for the offering of securities by GeoVax Labs, Inc., the registrant, to request that the Securities and Exchange Commission declare the above-captioned registration statement effective at 5:00 p.m., June 28, 2010, or as soon as practicable thereafter.

The Placement Agent hereby acknowledges that it is aware of its obligations under the Securities Act of 1933.

If you have any questions, please contact me at (504) 410-8017. Thank you for your time and attention.

Very truly yours,
GLOBAL HUNTER SECURITIES LLC

Show Raw Text
CORRESP
1
filename1.htm

corresp

GeoVax Labs, Inc.

1900 Lake Park Drive

Suite 380

Smyrna, Georgia 30080

(678) 384-7220

June 24, 2010

Mr. Jeffrey P. Riedler

Assistant Director

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    RE:

    GeoVax Labs, Inc.

    Registration Statement on Form S-1

    File No. 333-165828

Dear Mr. Riedler:

     In accordance with Rule 461, I am writing this letter on behalf of GeoVax Labs, Inc., the
registrant, to request that the Securities and Exchange Commission declare the above-captioned
registration statement effective at 5:00 p.m., June 28, 2010, or as soon as practicable thereafter.

     GeoVax Labs, Inc. (the “Company”) hereby acknowledges that:

    •

    it is aware of its obligations under the Securities Act of 1933;

    •

    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 with
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 the 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.

Mr. Jeffrey P. Riedler

June 24, 2010

Page 2

     If you have any questions, please contact me at 678-384-7224. Thank you for your time and
attention.

    Very truly yours,

GEOVAX LABS, INC.

    By:
    /s/ Mark W. Reynolds

    Mark W. Reynolds

    Chief Financial Officer

    cc:

    Nandini Acharya, Esq.

    Robert T. McNally, Ph.D.

    Clinton D. Richardson, Esq.

    T. Clark Fitzgerald III, Esq.

GLOBAL HUNTER SECURITIES LLC

400 Poydras Street, Suite 1510

New Orleans, Louisiana 70130

(504) 410-8010

June 24, 2010

Mr. Jeffrey P. Riedler

Assistant Director

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

          RE:

    GeoVax Labs, Inc.

Registration Statement on Form S-1

File No. 333-165828

Dear Mr. Riedler:

     In accordance with Rule 461, I am writing this letter on behalf of Global Hunter Securities
LLC, placement agent (the “Placement Agent”) for the offering of securities by GeoVax Labs,
Inc., the registrant, to request that the Securities and Exchange Commission declare the
above-captioned registration statement effective at 5:00 p.m., June 28, 2010, or as soon as
practicable thereafter.

     The Placement Agent hereby acknowledges that it is aware of its obligations under the
Securities Act of 1933.

     If you have any questions, please contact me at (504) 410-8017. Thank you for your time and
attention.

    Very truly yours,

GLOBAL HUNTER SECURITIES LLC

    By:
    /s/ Gary Meringer

    Gary Meringer

    Internal Counsel

    cc:

    Nandini Acharya, Esq.

Robert T. McNally, Ph.D.

Clinton D. Richardson, Esq.

T. Clark Fitzgerald III, Esq.

Shivbir Grewal, Esq.

Susan Krause, Esq.