SEC Comment Letter for INTELLINETICS, INC. (INLX) (CIK 0001081745) (INLX) — Mar 26, 2020
INTELLINETICS, INC. (INLX) (CIK 0001081745)
Date: March 26, 2020 · CIK: 0001081745 · Accession: 0000000000-20-002648
AI Filing Summary & Sentiment
File numbers found in text: 000-31671
Letter
March 26, 2020 James DeSocio Chief Executive Officer Intellinetics, Inc. 2190 Dividend Drive Columbus, Ohio 43228 Re:Intellinetics, Inc. Information Statement on Schedule 14C Filed March 17, 2020 File No. 000-31671 Dear Mr. DeSocio: We have reviewed your filing and have the following 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Information Statement on Schedule 14C Approval of an Amendment to our Articles of Incorporation... Reasons for the Reverse Split and Charter Amendments 1.We note your statement that the reverse split and charter amendments were necessary to effectuate the acquisition of Graphic Sciences, Inc. Therefore, it appears that you must provide the disclosures required by Item 14 of Schedule 14A regarding the transaction. Refer to Note A of Schedule 14A as well as Item 1 of Schedule 14C, which incorporates the disclosure requirements of Schedule 14A. Please revise to provide all such information or, alternatively, explain why you believe such disclosure is not required. 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. You may contact Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in his absence,
FirstName LastNameJames DeSocio Comapany NameIntellinetics, Inc. March 26, 2020 Page 2 FirstName LastName James DeSocio Intellinetics, Inc. March 26, 2020 Page 2 Jan Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require further assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815. Sincerely, Division of Corporation Finance Office of Technology cc: Erin C. Herbst, Esq.
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March 26, 2020
James DeSocio
Chief Executive Officer
Intellinetics, Inc.
2190 Dividend Drive
Columbus, Ohio 43228
Re:Intellinetics, Inc.
Information Statement on Schedule 14C
Filed March 17, 2020
File No. 000-31671
Dear Mr. DeSocio:
We have reviewed your filing and have the following 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Information Statement on Schedule 14C
Approval of an Amendment to our Articles of Incorporation...
Reasons for the Reverse Split and Charter Amendments
1.We note your statement that the reverse split and charter amendments were necessary to
effectuate the acquisition of Graphic Sciences, Inc. Therefore, it appears that you must
provide the disclosures required by Item 14 of Schedule 14A regarding the transaction.
Refer to Note A of Schedule 14A as well as Item 1 of Schedule 14C, which incorporates
the disclosure requirements of Schedule 14A. Please revise to provide all such
information or, alternatively, explain why you believe such disclosure is not required.
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.
You may contact Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in his absence,
FirstName LastNameJames DeSocio
Comapany NameIntellinetics, Inc.
March 26, 2020 Page 2
FirstName LastName
James DeSocio
Intellinetics, Inc.
March 26, 2020
Page 2
Jan Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Erin C. Herbst, Esq.