SEC Comment Letter for GENEREX BIOTECHNOLOGY CORP (CIK 0001059784) — Sep 8, 2020
GENEREX BIOTECHNOLOGY CORP (CIK 0001059784)
Date: Sept. 8, 2020 · CIK: 0001059784 · Accession: 0000000000-20-008406
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File numbers found in text: 333-236481, 333-248205
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United States securities and exchange commission logo
September 4, 2020
Joseph Moscato
Chief Executive Officer
Generex Biotechnology Corporation
10102 USA Today Way
Miramar, FL 33025
Re:Generex Biotechnology Corporation
Registration Statement on Form S-1
Filed August 20, 2020
File No. 333-248205
Dear Mr. Moscato:
We have limited our review of your registration statement to those issues we have
addressed in our comment. 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 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 these comments, we may have additional comments.
Registration Statement on Form S-1
General
1.As you know, the staff is reviewing your Registration Statement on Form S-1 filed on
February 18, 2020, File No. 333-236481, and have issued comments in connection with
that review. Please confirm that you will make corresponding changes to this registration
statement.
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
FirstName LastNameJoseph Moscato
Comapany NameGenerex Biotechnology Corporation
September 4, 2020 Page 2
FirstName LastName
Joseph Moscato
Generex Biotechnology Corporation
September 4, 2020
Page 2
statement.
Please contact Ada D. Sarmento at 202-551-3798 or Joe McCann at 202-551-6262 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences