Correspondence 0001683168-24-001235 from PRECISION OPTICS CORPORATION, INC. (POCI) (CIK 0000867840) (POCI)
PRECISION OPTICS CORPORATION, INC. (POCI) (CIK 0000867840)
Date: Feb. 28, 2024 · CIK: 0000867840 · Accession: 0001683168-24-001235
AI Filing Summary & Sentiment
File numbers found in text: 001-10647
Referenced dates: February 1, 2024, February 14, 2024
Letter
Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services Attention: Kristin Lochhead and Michael Fay Form 10-K for the Fiscal Year Ended June 30, 2023 File No. 001-10647
Re: Precision Optics Corporation
Dear Ms. Lochhead and Mr. Fay:
Please find below the response of Precision Optics Corporation, Inc. (the “Company,” “we” or “our”) to the comments raised by the staff of the Securities and Exchange Commission (the “Staff”) in its letter dated February 14, 2024, in reference to the earlier letter from the Staff dated February 1, 2024, and our subsequent response on February 8, 2024 regarding the above-referenced report. We have restated in italics below your comment, followed by our response.
Form 10-K for the Fiscal Year Ended June 30, 2023
1. COMMENT - We reference your response to prior comment 2 that you incorrectly disclosed that your internal control over financial reporting and disclosure controls and procedures were not effective as of June 30, 2023. Please amend your Form 10-K to include revised conclusions, as required by Items 307 and 308 of Regulation S-K. You may file an abbreviated amendment with only Item 9A. Please also include new Section 302 certifications and consider how this error in your disclosure impacts your future assessments of disclosure controls and procedures and internal control over financial reporting.
Response:
We have prepared an Amendment No. 1 to the Form 10-K with the revised conclusion and new Section 302 certifications. The Amendment was filed on February 28, 2024. We have evaluated the cause of the error and our disclosure controls and determined that our internal controls and procedures over financial reporting are adequate, and that the failure to notice the carryover of language from the prior year filing was an isolated error that does not undermine our confidence in the quality of our internal controls and procedures generally.
If the Staff has any questions regarding our responses or any additional comments, please feel free to contact me at (978) 630-1800 x161.
Yours Truly,
/s/ Wayne Coll
Wayne Coll
Chief Financial Officer
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February 28, 2024
Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
100 F Street, NE
Washington, D.C. 20549
Attention: Kristin Lochhead and Michael Fay
Re: Precision Optics Corporation
Form 10-K for the Fiscal Year Ended June 30, 2023
File No. 001-10647
Dear Ms. Lochhead and Mr. Fay:
Please find below the response of Precision Optics Corporation, Inc.
(the “Company,” “we” or “our”) to the comments raised by the staff of the Securities and Exchange
Commission (the “Staff”) in its letter dated February 14, 2024, in reference to the earlier letter from the Staff dated February
1, 2024, and our subsequent response on February 8, 2024 regarding the above-referenced report. We have restated in italics below your
comment, followed by our response.
Form 10-K for the Fiscal Year Ended June
30, 2023
1. COMMENT - We reference your response to prior comment 2 that you incorrectly disclosed that your internal control over financial
reporting and disclosure controls and procedures were not effective as of June 30, 2023. Please amend your Form 10-K to include revised
conclusions, as required by Items 307 and 308 of Regulation S-K. You may file an abbreviated amendment with only Item 9A. Please also
include new Section 302 certifications and consider how this error in your disclosure impacts your future assessments of disclosure controls
and procedures and internal control over financial reporting.
Response:
We have prepared an Amendment No. 1 to the Form 10-K with the revised
conclusion and new Section 302 certifications. The Amendment was filed on February 28, 2024. We have evaluated the cause of the error
and our disclosure controls and determined that our internal controls and procedures over financial reporting are adequate, and that the
failure to notice the carryover of language from the prior year filing was an isolated error that does not undermine our confidence in
the quality of our internal controls and procedures generally.
If the Staff has any questions regarding our responses or any additional
comments, please feel free to contact me at (978) 630-1800 x161.
Yours Truly,
/s/ Wayne Coll
Wayne Coll
Chief Financial Officer