SEC Comment Letter 0000000000-23-005281 to NovelStem International Corp. (NSTM) (CIK 0000912544) (NSTM)
NovelStem International Corp. (NSTM) (CIK 0000912544)
Date: May 17, 2023 · CIK: 0000912544 · Accession: 0000000000-23-005281
AI Filing Summary & Sentiment
File numbers found in text: 000-22908
Referenced dates: March 2, 2023
Letter
United States securities and exchange commission logo May 17, 2023 Jan Loeb Executive Chairman NovelStem International Corp. 2255 Glades Road Suite 221A Boca Raton, FL 33431 Re:NovelStem International Corp. Amendment No. 3 to Registration Statement on Form 10-12G Correspondence Filed April 26, 2023 File No. 000-22908 Dear Jan Loeb: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Amendment No. 3 to Registration Statement on Form 10-12G General 1.We note your response to comment 1 of our letter dated March 2, 2023 and reissue in part. Given that your ability to rely on Rule 3a-1 under the Investment Company Act will depend (among other things) on facts and circumstances regarding your control of NewStem, and that you retain significant investment company status risk, please enhance your investment company status risk disclosure to indicate that you intend to rely on Rule 3a-1 under the Investment Company Act and explain the basis for such reliance.
FirstName LastNameJan Loeb Comapany NameNovelStem International Corp. May 17, 2023 Page 2 FirstName LastName Jan Loeb NovelStem International Corp. May 17, 2023 Page 2 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 Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you have questions regarding comments on the financial statements and related matters. Please contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Morris DeFeo
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United States securities and exchange commission logo
May 17, 2023
Jan Loeb
Executive Chairman
NovelStem International Corp.
2255 Glades Road
Suite 221A
Boca Raton, FL 33431
Re:NovelStem International Corp.
Amendment No. 3 to Registration Statement on Form 10-12G
Correspondence Filed April 26, 2023
File No. 000-22908
Dear Jan Loeb:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Amendment No. 3 to Registration Statement on Form 10-12G
General
1.We note your response to comment 1 of our letter dated March 2, 2023 and reissue in part.
Given that your ability to rely on Rule 3a-1 under the Investment Company Act will
depend (among other things) on facts and circumstances regarding your control of
NewStem, and that you retain significant investment company status risk, please enhance
your investment company status risk disclosure to indicate that you intend to rely on Rule
3a-1 under the Investment Company Act and explain the basis for such reliance.
FirstName LastNameJan Loeb
Comapany NameNovelStem International Corp.
May 17, 2023 Page 2
FirstName LastName
Jan Loeb
NovelStem International Corp.
May 17, 2023
Page 2
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 Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Morris DeFeo