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SEC Company Response from VirnetX Holding Corp (VHC) (CIK 0001082324) (VHC) — Dec 17, 2009

VirnetX Holding Corp (VHC) (CIK 0001082324)
Date: Dec. 17, 2009 · CIK: 0001082324 · Accession: 0001019687-09-004591

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File numbers found in text: 333-162145

Date
Dec. 17, 2009
Author
VIRNETX
Form
CORRESP
Company
VirnetX Holding Corp (VHC) (CIK 0001082324)

Letter

virnet_corr-121709.htm

VIRNETX HOLDING CORPORATION

Scotts Valley Drive, Suite 110

Scotts Valley, California 95066

VIA EDGAR

December 17, 2009

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Ms. Barbara C. Jacobs, Assistant Director

Division of Corporate Finance

Re:

VirnetX Holding Corporation (Registration No. 333-162145)

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 S-1 to become effective at 5:00 p.m. Eastern Time, on December 21, 2009, 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 me at (831) 438-8200. Thank you for your prompt attention to this matter.

Sincerely,
VIRNETX
HOLDING CORPORATION

Show Raw Text
CORRESP
1
filename1.htm

    virnet_corr-121709.htm

    VIRNETX
HOLDING CORPORATION

    5615
Scotts Valley Drive, Suite 110

    Scotts
Valley, California  95066

    VIA
EDGAR

    December
17, 2009

    Division
of Corporation Finance

    United
States Securities and Exchange Commission

    100 F
Street, N.E.

    Washington,
D.C. 20549

                Attention:

                Ms.
      Barbara C. Jacobs, Assistant Director

                Division
      of Corporate Finance

                Re:

                VirnetX
      Holding Corporation (Registration No. 333-162145)

                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 S-1 to become effective at 5:00 p.m. Eastern Time, on December
21, 2009, 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 me at (831)
438-8200.  Thank you for your prompt attention to this
matter.

    Sincerely,

    VIRNETX
HOLDING CORPORATION

    By: /s/ Kendall Larsen

    Kendall
Larsen

    President
and Chief
Executive Officer