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CORRESP Filing

Aspira Women's Health Inc.
Date: May 6, 2025 · CIK: 0000926617 · Accession: 0001641172-25-008772

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File numbers found in text: 333-286561

Date
May 6, 2025
Author
Aspira
Form
CORRESP
Company
Aspira Women's Health Inc.

Letter

VIA EDGAR United States Securities and Exchange Commission Attention: Aspira Women's Health Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed April 30, 2025 File No. 333-286561

Dear Ladies and Gentlemen:

This letter sets forth a response on behalf of Aspira Women's Health Inc., a Delaware corporation (the "Company"), to the oral comments received on May 5, 2025 from the staff (the "Staff") of the Securities and Exchange Commission (the "Commission") with respect to the Company's above captioned Registration Statement on Form S-1 (the "Registration Statement"). This letter is being submitted together with Amendment No. 2 to the Registration Statement, which has been revised to address the Staff's comment. For the convenience of the Staff, the oral comment is restated below prior to the response to such comment.

Amendment No. 1 to Registration Statement on Form S-1 Filed on April 30, 2025

Risk Factors, page 8

1.

We note your disclosure on page 8 of this section that "before deciding whether to purchase our common stock, investors should carefully consider the risks described below together with the "Risk Factors" described in our most recent Annual Report on Form 10-K and any updates described in our Quarterly Reports on Form 10-Q and Current Reports on Form 8-K, all of which are incorporated herein by reference[.]" We note that at this time you appear to be ineligible to use incorporation by reference. Accordingly, please revise your disclosure here and elsewhere as appropriate to clarify that you are not using incorporation by reference in this Registration Statement or otherwise advise .

RESPONSE: The Company respectfully acknowledges the Staff's comment and has revised page 8 of the Registration Statement to clarify that we are not using incorporation by reference in this Registration Statement.

Sincerely,
Aspira
Women's Health Inc.

Show Raw Text
CORRESP
 1
 filename1.htm

 ASPIRA
WOMEN'S HEALTH INC.

 12117
Bee Caves Road, Building III, Suite 100

 Austin,
TX 78738

 May
6, 2025

 VIA
EDGAR

 United
States Securities and Exchange Commission

 100
F. Street, NE

 Washington,
DC 20549

 Attention:

 Joshua
 Gorsky

 Joe
 McCann

 Re:

 Aspira
 Women's Health Inc.

 Amendment
 No. 1 to Registration Statement on Form S-1

 Filed
 April 30, 2025

 File
 No. 333-286561

 Dear
Ladies and Gentlemen:

 This
letter sets forth a response on behalf of Aspira Women's Health Inc., a Delaware corporation (the "Company"), to the
oral comments received on May 5, 2025 from the staff (the "Staff") of the Securities and Exchange Commission (the "Commission")
with respect to the Company's above captioned Registration Statement on Form S-1 (the "Registration Statement"). This
letter is being submitted together with Amendment No. 2 to the Registration Statement, which has been revised to address the Staff's
comment. For the convenience of the Staff, the oral comment is restated below prior to the response to such comment.

 Amendment
No. 1 to Registration Statement on Form S-1 Filed on April 30, 2025

 Risk
Factors, page 8

 1.

 We
 note your disclosure on page 8 of this section that "before deciding whether to purchase our common stock, investors should
 carefully consider the risks described below together with the "Risk Factors" described in our most recent Annual Report
 on Form 10-K and any updates described in our Quarterly Reports on Form 10-Q and Current Reports on Form 8-K, all of which are incorporated
 herein by reference[.]" We note that at this time you appear to be ineligible to use incorporation by reference. Accordingly,
 please revise your disclosure here and elsewhere as appropriate to clarify that you are not using incorporation by reference in this
 Registration Statement or otherwise advise .

 RESPONSE:
 The
 Company respectfully acknowledges the Staff's comment and has revised page 8 of the Registration Statement to clarify that
 we are not using incorporation by reference in this Registration Statement.

 Sincerely,

 Aspira
 Women's Health Inc.

 /s/
 Michael Buhle

 By:
 Michael
 Buhle

 Title:
 Chief
 Executive Officer