SEC Comment Letter for ALR TECHNOLOGIES INC. (CIK 0001087022) — Apr 15, 2022
ALR TECHNOLOGIES INC. (CIK 0001087022)
Date: April 15, 2022 · CIK: 0001087022 · Accession: 0000000000-22-004074
AI Filing Summary & Sentiment
File numbers found in text: 000-30414
Letter
United States securities and exchange commission logo April 15, 2022 Sidney Chan Chief Executive and Chief Financial Officer ALR Technologies, Inc. 7400 Beaufont Springs Dr , Suite 300 Richmond , Virginia 23225 Re:ALR Technologies, Inc. Form 10-K for the Year Ended December 31, 2021 Filed March 22, 2022 File No. 000-30414 Dear Mr. Chan: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the Year Ended December 31, 2021 Item 9A. Controls and Procedures, page F-32 1.We note your conclusions that disclosure controls and procedures were effective but internal controls over financial reporting were ineffective. Please tell us how management was able to conclude that disclosure controls and procedures were effective given the substantial overlap with internal controls over financial reporting. Please refer to SEC Release No. 33-8238. Alternatively, please confirm that you will revise future filings to disclose consistent conclusions for both disclosure controls and procedures and internal controls over financial reporting. In closing, 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 Effie Simpson at (202) 551-3346 or Kevin Woody, Branch Chief, at
FirstName LastNameSidney Chan Comapany NameALR Technologies, Inc. April 15, 2022 Page 2 FirstName LastName Sidney Chan ALR Technologies, Inc. April 15, 2022 Page 2 (202) 551-3629 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Steven Brassard
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United States securities and exchange commission logo
April 15, 2022
Sidney Chan
Chief Executive and Chief Financial Officer
ALR Technologies, Inc.
7400 Beaufont Springs Dr , Suite 300
Richmond , Virginia 23225
Re:ALR Technologies, Inc.
Form 10-K for the Year Ended December 31, 2021
Filed March 22, 2022
File No. 000-30414
Dear Mr. Chan:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Year Ended December 31, 2021
Item 9A. Controls and Procedures, page F-32
1.We note your conclusions that disclosure controls and procedures were effective but
internal controls over financial reporting were ineffective. Please tell us how management
was able to conclude that disclosure controls and procedures were effective given the
substantial overlap with internal controls over financial reporting. Please refer to SEC
Release No. 33-8238. Alternatively, please confirm that you will revise future filings
to disclose consistent conclusions for both disclosure controls and procedures and internal
controls over financial reporting.
In closing, 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 Effie Simpson at (202) 551-3346 or Kevin Woody, Branch Chief, at
FirstName LastNameSidney Chan
Comapany NameALR Technologies, Inc.
April 15, 2022 Page 2
FirstName LastName
Sidney Chan
ALR Technologies, Inc.
April 15, 2022
Page 2
(202) 551-3629 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Steven Brassard