SEC Comment Letter for VIVEVE MEDICAL, INC. (VIVE) (CIK 0000879682) — May 20, 2020
VIVEVE MEDICAL, INC. (VIVE) (CIK 0000879682)
Date: May 20, 2020 · CIK: 0000879682 · Accession: 0000000000-20-004484
AI Filing Summary & Sentiment
File numbers found in text: 001-11388
Letter
United States securities and exchange commission logo May 19, 2020 Jim Robbins Vice President of Finance and Administration Viveve Medical, Inc. 345 Inverness Drive South Building B, Suite 250 Englewood, CO 80112 Re:Viveve Medical, Inc. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed March 19, 2020 File No. 001-11388 Dear Mr. Robbins: 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 Fiscal Year Ended December 31, 2019 Item 9A. Controls and Procedures, page 52 1.Please amend this filing to provide management’s annual report on internal control over financial reporting. Refer to Item 308 of Regulation S-K. Note the amendment should include updated Section 302 certifications. 2.Further to the above, please tell us how you have considered whether management's failure to complete and disclose its report on internal control over financial reporting impacts its conclusions regarding the effectiveness of your disclosure controls and procedures as of the end of the fiscal year covered by the report and revise your disclosure as appropriate. In this regard, discuss how you have considered the definition of disclosure controls and procedures provided in Rule 13a-15(e), which indicates that effective controls and procedures would ensure that information required to be disclosed
FirstName LastNameJim Robbins Comapany NameViveve Medical, Inc. May 19, 2020 Page 2 FirstName LastName Jim Robbins Viveve Medical, Inc. May 19, 2020 Page 2 by the issuer is recorded, processed, summarized and reported within the time periods specified in the Commission's rules and forms. Please note the guidance in Compliance and Disclosure Interpretation 115.02. 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 David Burton at (202) 551-3626 or Lynn Dicker, Senior Accountant, at (202) 551-3616 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
May 19, 2020
Jim Robbins
Vice President of Finance and Administration
Viveve Medical, Inc.
345 Inverness Drive South
Building B, Suite 250
Englewood, CO 80112
Re:Viveve Medical, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 19, 2020
File No. 001-11388
Dear Mr. Robbins:
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 Fiscal Year Ended December 31, 2019
Item 9A. Controls and Procedures, page 52
1.Please amend this filing to provide management’s annual report on internal control over
financial reporting. Refer to Item 308 of Regulation S-K. Note the amendment should
include updated Section 302 certifications.
2.Further to the above, please tell us how you have considered whether management's
failure to complete and disclose its report on internal control over financial reporting
impacts its conclusions regarding the effectiveness of your disclosure controls and
procedures as of the end of the fiscal year covered by the report and revise your disclosure
as appropriate. In this regard, discuss how you have considered the definition of
disclosure controls and procedures provided in Rule 13a-15(e), which indicates that
effective controls and procedures would ensure that information required to be disclosed
FirstName LastNameJim Robbins
Comapany NameViveve Medical, Inc.
May 19, 2020 Page 2
FirstName LastName
Jim Robbins
Viveve Medical, Inc.
May 19, 2020
Page 2
by the issuer is recorded, processed, summarized and reported within the time periods
specified in the Commission's rules and forms. Please note the guidance in Compliance
and Disclosure Interpretation 115.02.
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 David Burton at (202) 551-3626 or Lynn Dicker, Senior Accountant, at
(202) 551-3616 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences