SEC Comment Letter for ASTROTECH Corp (ASTC) (CIK 0001001907) (ASTC) — Jul 26, 2018
ASTROTECH Corp (ASTC) (CIK 0001001907)
Date: July 26, 2018 · CIK: 0001001907 · Accession: 0000000000-18-023093
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File numbers found in text: 333-226060
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July 26, 2018
Thomas B. Pickens
Chief Executive Officer
Astrotech Corporation
201 West 5th Street, Suite 1275
Austin, TX 78701
Re:Astrotech Corporation
Registration Statement on Form S-3
Filed June 3, 2018
File No. 333-226060
Dear Mr. Pickens:
We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Form S-3 filed on June 3, 2018
General
1.We note that you do not appear to be eligible to conduct a primary offering pursuant to
General Instruction I.B.1 of Form S-3. Please advise whether you believe you are eligible
to conduct a primary offering on Form S-3 pursuant to General Instruction I.B.1. To the
extent you do not meet the public float requirement in General Instruction I.B.1, and
instead intend to rely upon General Instruction I.B.6., please revise to include the
information required by Instruction 7 to General Instruction I.B.6 on the prospectus cover
page.
FirstName LastNameThomas B. Pickens
Comapany NameAstrotech Corporation
July 26, 2018 Page 2
FirstName LastName
Thomas B. Pickens
Astrotech Corporation
July 26, 2018
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Donald E. Field at 202-551-3680 or Susan Block at 202-551-3210 with
any questions.
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