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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: 0000950134-07-026042

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-145765

Date
December 21, 2007
Author
/s/
Form
CORRESP
Company
VirnetX Holding Corp (VHC) (CIK 0001082324)

Letter

Securities and Exchange Commission Attention: Jay Ingram VirnetX Holding Corporation Registration Number: 333-145765

Re:

Dear Mr. Ingram:

On behalf of Gilford Securities Incorporated, the managing underwriter in the above-referenced offering (the “Offering”), we hereby join VirnetX Holding Corporation (the “Company”) in requesting acceleration of the effective date of the Offering to Friday, December 21, 2007 at 3:00 p.m. (Eastern Time), or as soon as practicable thereafter.

In connection with this request, we hereby provide you with the following information pursuant to Rule 460 as promulgated under the Securities Act of 1933, as amended, with respect to the distribution to date of the Company’s preliminary prospectus dated December 17, 2007.

To Whom Distributed

Number of Copies

Brokers/Dealers

Institutional Investors

Retail Investors

This will further confirm that the undersigned has and will continue to comply with Rule 15c2-8 under the Securities and Exchange Act of 1934, as amended, with regard to the preliminary prospectus.

Sincerely,
/s/
Robert A. Maley

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CORRESP
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filename1.htm

corresp

[Gilford Securities Incorporated Letterhead]

December 21, 2007

Securities and Exchange Commission

450 Fifth Street, NW

Washington, D.C. 20549

Attention: Jay Ingram

    Re:

    VirnetX Holding Corporation

    Registration Number: 333-145765

Dear
Mr. Ingram:

     On behalf of Gilford Securities Incorporated, the managing underwriter in the
above-referenced offering (the “Offering”), we hereby join VirnetX Holding
Corporation (the “Company”) in requesting acceleration of the effective date of the
Offering to Friday, December 21, 2007 at 3:00 p.m. (Eastern Time), or as soon as
practicable thereafter.

     In connection with this request, we hereby provide you with the following information
pursuant to Rule 460 as promulgated under the Securities Act of 1933, as amended, with
respect to the distribution to date of the Company’s preliminary
prospectus dated December 17, 2007.

    To Whom Distributed

    Number of Copies

    Brokers/Dealers

    600

    Institutional Investors

    50

    Retail Investors

    100

     This will further confirm that the undersigned has and will continue to comply with
Rule 15c2-8 under the Securities and Exchange Act of 1934, as amended, with regard to the
preliminary prospectus.

Sincerely,

/s/
Robert A. Maley

Robert A. Maley

President