SEC Company Response from VirnetX Holding Corp (VHC) (CIK 0001082324) (VHC) — Dec 21, 2007
VirnetX Holding Corp (VHC) (CIK 0001082324)
Date: Dec. 21, 2007 · CIK: 0001082324 · Accession: 0000950134-07-026041
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-145765
Letter
VIRNETX HOLDING CORPORATION
5615 Scotts Valley Drive, Suite 110
Scotts Valley, CA 95066
VIA EDGAR AND FACSIMILE
December 21, 2007
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Mr. Jay Ingram
Division of Corporate Finance
Re:
VirnetX Holding Corporation (Registration No. 333-145765)
Acceleration Request
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, VirnetX Holding Corporation (the “Corporation”) hereby requests acceleration of the effectiveness of the above-referenced Registration Statement on Form SB-2 to become effective at 3:00 p.m. Eastern Time, on Friday, December 21, 2007 or as soon as reasonably practicable thereafter.
In connection with this request, the Corporation acknowledges that:
•
should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with 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 Corporation from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•
the Corporation may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions or comments, please contact Lowell D. Ness at (650) 614-7455 of Orrick, Herrington & Sutcliffe LLP, the Corporation’s outside counsel. Thank you for your prompt attention to this matter.
Sincerely,
VIRNETX HOLDING CORPORATION
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CORRESP
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corresp
VIRNETX
HOLDING CORPORATION
5615 Scotts Valley Drive, Suite 110
Scotts Valley, CA 95066
VIA EDGAR AND FACSIMILE
December 21, 2007
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Mr. Jay Ingram
Division of Corporate Finance
Re:
VirnetX Holding Corporation (Registration No. 333-145765)
Acceleration Request
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as
amended, VirnetX Holding Corporation (the “Corporation”) hereby requests acceleration of the
effectiveness of the above-referenced Registration Statement on Form SB-2 to become effective at
3:00 p.m. Eastern Time, on Friday, December 21, 2007 or as soon as reasonably practicable
thereafter.
In connection with this request, the Corporation
acknowledges that:
•
should the Securities and Exchange Commission (the “Commission”) or the staff, acting
pursuant to delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with 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 Corporation from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and
•
the Corporation may not assert this action as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
If you have any questions or comments, please contact Lowell D. Ness at (650) 614-7455 of Orrick,
Herrington & Sutcliffe LLP, the Corporation’s outside counsel. Thank you for your prompt attention
to this matter.
Sincerely,
VIRNETX HOLDING CORPORATION
By:
/s/ Kendall Larsen
Kendall Larsen
President and
Chief Executive Officer