SEC Comment Letter for INTELLINETICS, INC. (INLX) (CIK 0001081745) (INLX) — Apr 26, 2016
INTELLINETICS, INC. (INLX) (CIK 0001081745)
Date: April 26, 2016 · CIK: 0001081745 · Accession: 0000000000-16-073770
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File numbers found in text: 333-210484
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Mail Stop 4561
April 26, 2016
Matthew L. Chretien
President and Chief Executive Officer
Intellinetics , Inc.
2190 Dividend Drive
Columbus, OH 43228
Re: Intellinetics, Inc.
Registration Statement on Form S-1
Filed March 30, 2016
File No. 333-210484
Dear Mr. Chretien :
This is to advise you that we have not reviewed and will not review your registration
statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities Act rules require. Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In the event you request acceleration of the effective date of the pending regist ration
statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in th e filing; and
the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Please refer to Rule 461 regard ing requests for acceleration . We will consider a written
request for acceleration of the effective date of the registration statement as confirmation of the
fact that those requesting acceleration are aware of their respective responsibilities under the
Matthew L. Chretien
Intellinetics , Inc.
April 26, 2016
Page 2
Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .
Please contact Gabriel Eckstein at (202) 551 -3286 with any questions.
Sincerely,
/s/ Barbara C. Jacobs
Barbara C. Jacobs
Assistant Director
Office of Information
Technologies and Services
cc: Erin C. Herbst , Esq.
Kegler Brown Hill & Ritter Co., L.P.A.