SEC Comment Letter for Cryoport, Inc. (CYRX) (CIK 0001124524) (CYRX) — Aug 24, 2018
Cryoport, Inc. (CYRX) (CIK 0001124524)
Date: Aug. 24, 2018 · CIK: 0001124524 · Accession: 0000000000-18-026461
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4628 August 24 , 2018 Via E-Mail Robert F. Stefanovich Chief Financial Officer Cryoport, Inc. 17305 Daimler Street Irvine , CA 9 2614
Re: Cryoport, Inc. Form 10-K for the Fiscal Year Ended December 3 1, 2017 Filed March 8 , 2018 File No. 1-34632
Dear Mr. Stefanovich :
We have limited our review of your filing to your contacts with countries that have been identified as state sponsors of terrorism, and we have the following comments. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. In our comments , we ask you to provide us with information so we may better understand your disclosu re.
Please respond to these comments within ten busine ss days by providing the requested information or advis e 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 y our response.
After reviewing your response to these comments, we may have additional comments.
General
1. On page 6, you identify DHL, FedEx and UPS as companies with which you have strategic logistics alliances through which these companies’ customers may ship using Cryoport services. Each of these companies provides shipping services to and/or from Syria an d Sudan. Also, your website includes a document titled “Challenges in International Shipping” which includes Syria in a list of countries that have guidelines in place relating specifically to cold chain distribution of pharmaceuticals and other materials . Syria and Sudan are designated by the State Department as state sponsors of terrorism and are subject to U.S. sanctions and/or export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with Syria and Su dan, including with their governments, whether through subsidiaries, customers, strategic logistics alliance partners, affiliates, or other direct or indirect arrangements.
Robert F. Stefanovich Cryoport, Inc. August 24 , 2018 Page 2
We remind you that the company and its management are responsible for the acc uracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 - 3470 if you have any questions about the comment s or our review.
Sincerely,
/s/ Cecilia Bl ye
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Mail Stop 4628 August 24 , 2018 Via E-Mail Robert F. Stefanovich Chief Financial Officer Cryoport, Inc. 17305 Daimler Street Irvine , CA 9 2614 Re: Cryoport, Inc. Form 10-K for the Fiscal Year Ended December 3 1, 2017 Filed March 8 , 2018 File No. 1-34632 Dear Mr. Stefanovich : We have limited our review of your filing to your contacts with countries that have been identified as state sponsors of terrorism, and we have the following comments. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. In our comments , we ask you to provide us with information so we may better understand your disclosu re. Please respond to these comments within ten busine ss days by providing the requested information or advis e 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 y our response. After reviewing your response to these comments, we may have additional comments. General 1. On page 6, you identify DHL, FedEx and UPS as companies with which you have strategic logistics alliances through which these companies’ customers may ship using Cryoport services. Each of these companies provides shipping services to and/or from Syria an d Sudan. Also, your website includes a document titled “Challenges in International Shipping” which includes Syria in a list of countries that have guidelines in place relating specifically to cold chain distribution of pharmaceuticals and other materials . Syria and Sudan are designated by the State Department as state sponsors of terrorism and are subject to U.S. sanctions and/or export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with Syria and Su dan, including with their governments, whether through subsidiaries, customers, strategic logistics alliance partners, affiliates, or other direct or indirect arrangements. Robert F. Stefanovich Cryoport, Inc. August 24 , 2018 Page 2 We remind you that the company and its management are responsible for the acc uracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 - 3470 if you have any questions about the comment s or our review. Sincerely, /s/ Cecilia Bl ye Cecilia Blye, Chief Office of Global Security Risk cc: Anne Nguyen Parker Assistant Director