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SEC Comment Letter for AIM ImmunoTech Inc. (AIM) (CIK 0000946644) (AIM) — Sep 26, 2019

AIM ImmunoTech Inc. (AIM) (CIK 0000946644)
Date: Sept. 26, 2019 · CIK: 0000946644 · Accession: 0000000000-19-013949

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File numbers found in text: 333-233657

Date
September 24, 2019
Author
Christine Westbrook
Form
UPLOAD
Company
AIM ImmunoTech Inc. (AIM) (CIK 0000946644)

Letter

September 24, 2019 Thomas K. Equels Chief Executive Officer and President AIM ImmunoTech Inc. 2117 SW Highway 484 Ocala, FL 34473 Re:AIM ImmunoTech Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed September 24, 2019 File No. 333-233657 Dear Mr. Equels: We have reviewed your amended registration statement 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 letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to the comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 24, 2019 letter. Amendment No. 2 to Registration Statement on Form S-1 filed on September 24, 2019 Cover page 1.We note your response to comment 1 and your disclosure indicating you may decide to extend the offering period beyond ten days from the date of the prospectus. Please revise your disclosure to provide a termination date that is not indefinite.

FirstName LastNameThomas K. Equels Comapany NameAIM ImmunoTech Inc. September 24, 2019 Page 2 FirstName LastName Thomas K. Equels AIM ImmunoTech Inc. September 24, 2019 Page 2 Please contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at 202-551- 3625 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance cc: Rick Feiner, Esq.

Show Raw Text
September 24, 2019
Thomas K. Equels
Chief Executive Officer and President
AIM ImmunoTech Inc.
2117 SW Highway 484
Ocala, FL 34473
Re:AIM ImmunoTech Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed September 24, 2019
File No. 333-233657
Dear Mr. Equels:
            We have reviewed your amended registration statement 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 letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our September 24, 2019 letter.
Amendment No. 2 to Registration Statement on Form S-1 filed on September 24, 2019
Cover page
1.We note your response to comment 1 and your disclosure indicating you may decide to
extend the offering period beyond ten days from the date of the prospectus. Please revise
your disclosure to provide a termination date that is not indefinite.

 FirstName LastNameThomas K. Equels
 Comapany NameAIM ImmunoTech Inc.
 September 24, 2019 Page 2
 FirstName LastName
Thomas K. Equels
AIM ImmunoTech Inc.
September 24, 2019
Page 2
            Please contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at 202-551-
3625 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Rick Feiner, Esq.