SEC Comment Letter for VirnetX Holding Corp (VHC) (CIK 0001082324) (VHC) — Nov 8, 2012
VirnetX Holding Corp (VHC) (CIK 0001082324)
Date: Nov. 8, 2012 · CIK: 0001082324 · Accession: 0000000000-12-061163
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File numbers found in text: 001-33852
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November 7 , 2012 Via E-mail Mr. Kendall Larsen President & Chief Executive Officer VirnetX Holding Corporation 308 Dorla Court Suite 206 Zephyr Cove, NV 89448 Re: VirnetX Holding Corporation . Form 10-K for the Fiscal Year Ended December 31, 201 1 Filed February 2 9, 2012 File No. 001-33852 Dear Mr. Larsen: We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities la ws of the United States. 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 Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief cc: Via E -mail Brad Finkelstein Wilson Sonsini Goodrich & Rosati