Correspondence 0001683168-24-004476 from Koil Energy Solutions, Inc. (KLNG) (CIK 0001110607) (KLNG)
Koil Energy Solutions, Inc. (KLNG) (CIK 0001110607)
Date: June 26, 2024 · CIK: 0001110607 · Accession: 0001683168-24-004476
AI Filing Summary & Sentiment
File numbers found in text: 000-30351
Referenced dates: June 17, 2024
Letter
June 26, 2024
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-4628
Attention:
Melissa Walsh and Stephen Krikorian
Division of Corporation Finance
Office of Technology
Re: Koil Energy Solutions, Inc.
Form 10-K for the Fiscal Year Ended December 31,
File No. 000-30351
Ladies and Gentlemen:
On behalf of Koil Energy Solutions, Inc. (the “Company”), I am responding to the Staff’s comments contained in the Staff’s letter dated June 17, 2024 relating to the referenced filing. The Company’s responses are set forth below the Staff’s comments. References herein to changes made in Amendment No. 1 refer to the Company’s Form 10-K/A, Amendment No. 1, filed contemporaneously herewith.
Controls and Procedures
Management's Report on Internal Control Over Financial Reporting, page 17
Comment 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.
Response: Management’s conclusion on the effectiveness of the Company’s internal controls is included under the referenced caption in Amendment No. 1.
Exhibit 31
Certifications Pursuant to Rules 13a-14(a) and 15d-14(a) of the Securities Exchange Act of 1934, page 27
Comment 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.
Response: The requested change has been made in the certifications filed as Exhibits 31.1 and 31.2 to Amendment No. 1, and the Company will make this change in future filings.
1310 RANKIN ROAD / HOUSTON, TX 77073 / O: 281.862.2201
WWW.KOILENERGY.COM
Comment 3: Please revise future filings to use the word “registrant” instead of the “Company” in
the certification.
Response: The requested change has been made in the certification filed as Exhibit 31 to Amendment No. 1, and the Company will make this change in future filings.
If you have any questions or require any additional information with respect to the foregoing, please contact the undersigned at tashurst@koilenergy.com.
Sincerely,
/s/ Trevor Ashurst
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June 26, 2024
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-4628
Attention:
Melissa Walsh and Stephen Krikorian
Division of Corporation Finance
Office of Technology
Re: Koil Energy Solutions, Inc.
Form 10-K for the Fiscal Year Ended December 31,
2023
File No. 000-30351
Ladies and Gentlemen:
On behalf of Koil Energy Solutions,
Inc. (the “Company”), I am responding to the Staff’s comments contained in the Staff’s letter dated June
17, 2024 relating to the referenced filing. The Company’s responses are set forth below the Staff’s comments. References herein
to changes made in Amendment No. 1 refer to the Company’s Form 10-K/A, Amendment No. 1, filed contemporaneously herewith.
Controls and Procedures
Management's Report on Internal Control Over
Financial Reporting, page 17
Comment 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.
Response: Management’s conclusion on
the effectiveness of the Company’s internal controls is included under the referenced caption in Amendment No. 1.
Exhibit 31
Certifications Pursuant to Rules 13a-14(a)
and 15d-14(a) of the Securities Exchange Act of 1934, page 27
Comment 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.
Response: The requested change has been made
in the certifications filed as Exhibits 31.1 and 31.2 to Amendment No. 1, and the Company will make this change in future filings.
1310 RANKIN ROAD
/ HOUSTON, TX 77073 / O: 281.862.2201
WWW.KOILENERGY.COM
Comment 3: Please revise future filings to use
the word “registrant” instead of the “Company” in
the certification.
Response: The requested change has been made
in the certification filed as Exhibit 31 to Amendment No. 1, and the Company will make this change in future filings.
If you have any questions
or require any additional information with respect to the foregoing, please contact the undersigned at tashurst@koilenergy.com.
Sincerely,
/s/ Trevor Ashurst
Vice President of Finance
cc: Erik Wiik
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