SEC Company Response from CREATIVE MEDICAL TECHNOLOGY HOLDINGS, INC. (CELZ) (CIK 0001187953) (CELZ) — Jan 30, 2018
CREATIVE MEDICAL TECHNOLOGY HOLDINGS, INC. (CELZ) (CIK 0001187953)
Date: Jan. 30, 2018 · CIK: 0001187953 · Accession: 0001144204-18-004716
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-53500
Letter
Division of Corporate Finance Office of Healthcare & Insurance Re: Creative Medical Technology Holdings, Inc. Amended Preliminary Information Statement on Schedule 14C Filed January 23, 2018 File No. 000-53500
Dear Ms. Paik and Ms. Jaskot:
Pursuant to my telephone conversations with Ms. Paik on January 30, 2018 during which we discussed the final comment to the PRER 14C Information Statement filed on January 23, 2018 (the “PRER 14C”) by Creative Medical Technology Holdings, Inc., a Nevada corporation (the “Company”), a DEF 14C Information Statement was filed on January 30, 2018 and the only revision that was made from the PRER 14C was the following disclosure was revised as follows:
$50,000 Secured Convertible Note
On June 26, 2017, the Company entered into a convertible note agreement with a lender for an aggregate principal amount of $50,000, for which $50,000 in proceeds were received on June 26, 2017. Under the terms of the agreement, the convertible note incurs interest at 12% per annum and has a maturity date of December 26, 2017. The convertible note is convertible upon issuance and convertible into shares of the Company’s stock at a conversion price equal to or greater than $0.25 or a conversion price equal to 60% of the average closing trading price of the Company’s common stock during the previous 20 trading days preceding the conversion date.
The conversion price is subject to adjustment in the case of stock splits, stock dividends, combinations of shares and similar recapitalization transactions and any issuances of securities below the conversion price of the convertible note. As of January 8, 2018, 148,553,067 no shares were reserved with our transfer agent with a potential of up to 151,179,304 being reserved if and when the lender issues a request to our transfer agent.
We hereby acknowledge the following on behalf of the Company:
· the Company is responsible for the adequacy and accuracy of the disclosure in the filing:
Ms. Irene Paik
Ms. Erin Jaskot
Page 2
· staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
· the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please feel free to contact me if you have any questions on the responses to your comment.
Sincerely,
/s/ Brian Higley
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CORRESP
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Vance,
Higley & Associates, P. C.
Attorneys at Law
1656
Reunion Avenue
SUITE 250
South
Jordan, UTAH 84095
Ronald N. Vance
TELEPHONE (801) 446-8802
Brian M. Higley
FAX (801) 446-8803
EMAIL: ron@vancelaw.us
EMAIL: brian@vancelaw.us
January 30, 2018
Ms. Irene Paik
Ms. Erin Jaskot
U.S. Securities and Exchange Commission
Division of Corporate Finance
Office of Healthcare & Insurance
Washington, DC 20549
Re: Creative Medical Technology Holdings, Inc.
Amended Preliminary Information
Statement on Schedule 14C
Filed January 23, 2018
File No. 000-53500
Dear Ms. Paik and Ms. Jaskot:
Pursuant to my telephone
conversations with Ms. Paik on January 30, 2018 during which we discussed the final comment to the PRER 14C Information Statement
filed on January 23, 2018 (the “PRER 14C”) by Creative Medical Technology Holdings, Inc., a Nevada corporation
(the “Company”), a DEF 14C Information Statement was filed on January 30, 2018 and the only revision that was
made from the PRER 14C was the following disclosure was revised as follows:
$50,000 Secured
Convertible Note
On June 26,
2017, the Company entered into a convertible note agreement with a lender for an aggregate principal amount of $50,000, for which
$50,000 in proceeds were received on June 26, 2017. Under the terms of the agreement, the convertible note incurs interest at 12%
per annum and has a maturity date of December 26, 2017. The convertible note is convertible upon issuance and convertible into
shares of the Company’s stock at a conversion price equal to or greater than $0.25 or a conversion price equal to 60% of
the average closing trading price of the Company’s common stock during the previous 20 trading days preceding the conversion
date.
The conversion
price is subject to adjustment in the case of stock splits, stock dividends, combinations of shares and similar recapitalization
transactions and any issuances of securities below the conversion price of the convertible note. As of January 8, 2018, 148,553,067 no shares were reserved with our transfer agent with a potential of up to 151,179,304 being reserved if and when the lender
issues a request to our transfer agent.
We hereby acknowledge
the following on behalf of the Company:
· the Company is responsible for the adequacy and accuracy
of the disclosure in the filing:
Ms. Irene Paik
Ms. Erin Jaskot
Page 2
· staff comments or changes to disclosure in response
to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
· the Company may not assert staff comments as a defense
in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please feel free to
contact me if you have any questions on the responses to your comment.
Sincerely,
/s/ Brian Higley
cc: Timothy Warbington, CEO
Donald
Dickerson, CFO