SEC Comment Letter 0000000000-24-006947 to Koil Energy Solutions, Inc. (KLNG) (CIK 0001110607) (KLNG)
Koil Energy Solutions, Inc. (KLNG) (CIK 0001110607)
Date: June 17, 2024 · CIK: 0001110607 · Accession: 0000000000-24-006947
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File numbers found in text: 000-30351
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United States securities and exchange commission logo
June 17, 2024
Trevor Ashurst
Vice President of Finance
Koil Energy Solutions, Inc.
1310 Rankin Road
Houston, TX 77073
Re:Koil Energy Solutions, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 000-30351
Dear Trevor Ashurst:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Controls and Procedures
Management's Report on Internal Control Over Financial Reporting, page 17
1.Please revise to disclose management’s conclusion on the effectiveness of your internal
controls over financial reporting. Refer to Item 308(a)(3) of Regulation S-K.
Exhibit 31
Certifications Pursuant to Rules 13a-14(a) and 15d-14(a) of the Securities Exchange Act of 1934,
page 27
2.We note that the identification of the certifying individual at the beginning of the
certification required by Exchange Act Rule 13a-14(a) also includes the title of the
certifying individual. In future filings, the identification of the certifying individual at the
beginning of the certification should be revised so as not to include the individual’s title.
3.Please revise future filings to use the word “registrant" instead of the "Company” in
the certification.
FirstName LastNameTrevor Ashurst
Comapany NameKoil Energy Solutions, Inc.
June 17, 2024 Page 2
FirstName LastName
Trevor Ashurst
Koil Energy Solutions, Inc.
June 17, 2024
Page 2
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.
Please contact Melissa Walsh at 202-551-3224 or Stephen Krikorian at 202-551-3488
with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Erik Wiik