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SEC Comment Letter for NextPlat Corp (NXPL) (CIK 0001058307) (NXPL) — Feb 19, 2015

NextPlat Corp (NXPL) (CIK 0001058307)
Date: Feb. 19, 2015 · CIK: 0001058307 · Accession: 0000000000-15-010447

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
Feb. 19, 2015
Author
/s/ Celeste M. Murphy for
Form
UPLOAD
Company
NextPlat Corp (NXPL) (CIK 0001058307)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE February 19, 201 5 Via E -mail David Rector Chief Executive Officer Orbital Tracking Corp . 1990 N. California Boulevard, 8th Floor Walnut Creek, California 94596

Re: Orbital Tracking Corp . Amendment No. 2 to Current Report on Form 8-K Filed Febr uary 10, 2015 File No. 0-25097

Dear M r. Rector :

We have reviewed your amended filing an d have the following comment . In the comment , we ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter by providing the requested information . If you d o not believe our comment applies to your facts a nd circumstances, please tell us why in your response.

After reviewing the information you provide in response to this comment , we may have additional comment s.

We may pursue strategic transactions in the future . . . , page 7

1. In your response to prior comment 4, you seem to suggest that it is unlikely that you will remain in the satellite communication business if you are not successful in your negotiations to merge with GTCL. Please confirm or clarify in your response. Also please clarify the specific business reasons for this plan to acquire or be acquired by GTCL and explain whether these plans were closely tied to the original asset purchas e agreement and license agreement with GTC. In this connection, please clarify why David Phipps has agreed to work as a consultant for the company without compensation.

You may contact Inessa Kessman , Staff Accountant, at (202) 5 51-3371 or Ivette Leon, Assistant Chief Accountant , at (202) 551 -3351 if you have questions relating to the

David Rector Great West Resources, Inc. February 19 , 201 5 Page 2

financial statements. Please contact Gregory Dundas , Attorney -Advisor, at (202) 551 -3436 , Celeste M. Murphy , Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 -3810 with any other questions.

Sincerely,
/s/ Celeste M. Murphy for

Show Raw Text
UNITED STATES
SECURITIES  AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
  CORPORATION FINANCE

February 19, 201 5

Via E -mail
David Rector
Chief Executive  Officer
Orbital Tracking Corp .
1990 N. California Boulevard, 8th Floor
Walnut Creek, California 94596

Re: Orbital Tracking Corp .
  Amendment No. 2  to Current Report  on Form 8-K
  Filed Febr uary 10, 2015
  File No. 0-25097

Dear M r. Rector :

We have reviewed your amended filing an d have the following comment .  In the
comment , we ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter by providing the requested information .  If you d o not
believe our comment  applies  to your facts a nd circumstances, please tell us why in your
response.

After reviewing the information you provide in response to this comment , we may
have  additional comment s.

We may pursue strategic transactions in the future . . . , page 7

1. In your response to prior comment 4, you seem to suggest that it is unlikely that you
will remain in the satellite communication business if you are not successful in your
negotiations to merge with GTCL.  Please confirm or clarify in your response.  Also
please clarify the specific business reasons for this plan to acquire or be acquired by
GTCL and explain whether these plans were closely tied to the original asset
purchas e agreement and license agreement with GTC.  In this connection, please
clarify why David Phipps has agreed to work as a consultant for the company without
compensation.

 You may contact Inessa Kessman , Staff Accountant, at (202) 5 51-3371 or Ivette
Leon, Assistant Chief Accountant , at (202) 551 -3351 if you have questions relating to the

David Rector
Great West Resources, Inc.
February 19 , 201 5
Page 2

financial statements.  Please contact Gregory Dundas , Attorney -Advisor,  at (202) 551 -3436 ,
Celeste M. Murphy , Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 -3810 with
any other questions.

Sincerely,

        /s/ Celeste M. Murphy for

Larry Spirgel
Assistant Director