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SEC Company Response from Sonnet BioTherapeutics Holdings, Inc. (SONN) (CIK 0001106838) — Feb 10, 2020

Sonnet BioTherapeutics Holdings, Inc. (SONN) (CIK 0001106838)
Date: Feb. 10, 2020 · CIK: 0001106838 · Accession: 0001493152-20-001898

AI Filing Summary & Sentiment

File numbers found in text: 333-235301

Date
Feb. 10, 2020
Author
Chief
Form
CORRESP
Company
Sonnet BioTherapeutics Holdings, Inc. (SONN) (CIK 0001106838)

Letter

VIA EDGAR CORRESPONDENCE Office of Trade and Services Division of Corporate Finance United States Securities Exchange Commission Re: Chanticleer Holdings, Inc. Registration Statement on Form S-4 Filed November 27, 2019 and amended February 7, 2020 File No. 333-235301 (“Registration Statement”)

Dear Ms. Bagley:

Pursuant to Rule 460 and Rule 461 under the Securities Act of 1933, as amended, Chanticleer Holdings, Inc., a Delaware corporation (the “Company”), hereby requests that the effective date of the above referenced Registration Statement be accelerated so that it will become effective at 4 p.m. Eastern time on Tuesday, February 11, 2020, or as soon thereafter as practicable.

The Company acknowledges that:

● should the Securities and Exchange Commission (“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 Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

● the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very
truly yours,
CHANTICLEER
HOLDINGS, INC.,

Show Raw Text
CORRESP
1
filename1.htm

CHANTICLEER
HOLDINGS, INC.

7621
Little Avenue, Suite 414

Charlotte,
NC 28226

(704)
366-5122

February
10, 2020

VIA
EDGAR CORRESPONDENCE

Katherine
Bagley

Office
of Trade and Services

Division
of Corporate Finance

United
States Securities Exchange Commission

Washington
D.C. 20549

Re:
Chanticleer Holdings, Inc.

Registration
Statement on Form S-4

Filed
November 27, 2019 and amended February 7, 2020

File
No. 333-235301 (“Registration Statement”)

Dear
Ms. Bagley:

Pursuant
to Rule 460 and Rule 461 under the Securities Act of 1933, as amended, Chanticleer Holdings, Inc., a Delaware corporation (the
“Company”), hereby requests that the effective date of the above referenced Registration Statement be accelerated
so that it will become effective at 4 p.m. Eastern time on Tuesday, February 11, 2020, or as soon thereafter as practicable.

The
Company acknowledges that:

 ● should
                                         the Securities and Exchange Commission (“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 Company from its full responsibility for the
                                         adequacy and accuracy of the disclosure in the filing; and

 ● the
                                         Company may not assert staff comments and the declaration of effectiveness as a defense
                                         in any proceeding initiated by the Commission or any person under the federal securities
                                         laws of the United States.

Very
truly yours,

    CHANTICLEER
    HOLDINGS, INC.,

    a
    Delaware corporation

    /s/
    Michael D. Pruitt

    By:

    Michael
    D. Pruitt

    Its:

    Chief
    Executive Officer and Chairman