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SEC Comment Letter 0000000000-25-002875 to Polomar Health Services, Inc. (PMHS)

Polomar Health Services, Inc.
Date: March 17, 2025 · CIK: 0001265521 · Accession: 0000000000-25-002875

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File numbers found in text: 000-56555

Date
March 17, 2025
Author
Division of
Form
UPLOAD
Company
Polomar Health Services, Inc.

Letter

Re: Polomar Health Services, Inc. Amendment No. 1 to the Form 10-Q for the Period Ended September 30, File No. 000-56555 Dear Terrence M. Tierney:

March 17, 2025

Terrence M. Tierney President and Chief Financial Officer Polomar Health Services, Inc. 10940 Wilshire Blvd. Suite 1500 Los Angeles, CA 90024

We have reviewed your March 7, 2025 response to our comment letter and have the following comment.

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. Unless we note otherwise, any references to prior comments are to comments in our December 17, 2024 letter.

Amendment No. 1 to the Form 10-Q for the Period Ended September 30, 2024 License Agreement Valuation, page F-7

1. We note your response to prior comment 2 in which you indicate that you have eliminated the section regarding "Merger Valuation" and adjusted the value of intellectual property and other intangible assets in your amended Form 10-Q for the Period Ended September 30, 2024. We also note that in your Form 10-Q for the Period Ended September 30, 2024, filed on November 19, 2024, you disclosed that as of the date of the filing the license agreement had no value, and you did not record any other intangible assets on your balance sheet. In light of prior reporting, please tell us your basis, with reference to accounting literature, for recording intellectual property and other intangible assets as of September 30, 2024. In this regard, please provide us a detailed analysis to show how you valued intellectual property and other intangible assets. March 17, 2025 Page 2

Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202- 551-3361 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Technology

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 17, 2025

Terrence M. Tierney
President and Chief Financial Officer
Polomar Health Services, Inc.
10940 Wilshire Blvd.
Suite 1500
Los Angeles, CA 90024

 Re: Polomar Health Services, Inc.
 Amendment No. 1 to the Form 10-Q for the Period Ended September 30,
2024
 File No. 000-56555
Dear Terrence M. Tierney:

 We have reviewed your March 7, 2025 response to our comment letter and
have the
following comment.

 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.
Unless we note otherwise, any references to prior comments are to comments in
our
December 17, 2024 letter.

Amendment No. 1 to the Form 10-Q for the Period Ended September 30, 2024
License Agreement Valuation, page F-7

1. We note your response to prior comment 2 in which you indicate that you
have
 eliminated the section regarding "Merger Valuation" and adjusted the
value of
 intellectual property and other intangible assets in your amended Form
10-Q for the
 Period Ended September 30, 2024. We also note that in your Form 10-Q for
the
 Period Ended September 30, 2024, filed on November 19, 2024, you
disclosed that as
 of the date of the filing the license agreement had no value, and you
did not record
 any other intangible assets on your balance sheet. In light of prior
reporting, please tell
 us your basis, with reference to accounting literature, for recording
intellectual
 property and other intangible assets as of September 30, 2024. In this
regard, please
 provide us a detailed analysis to show how you valued intellectual
property and other
 intangible assets.
 March 17, 2025
Page 2

 Please contact Anastasia Kaluzienski at 202-551-3685 or Robert
Littlepage at 202-
551-3361 if you have questions regarding comments on the financial statements
and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
</TEXT>
</DOCUMENT>