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SEC Comment Letter for Sintx Technologies, Inc. (SINT) (CIK 0001269026) (SINT) — Dec 3, 2015

Sintx Technologies, Inc. (SINT) (CIK 0001269026)
Date: Dec. 3, 2015 · CIK: 0001269026 · Accession: 0000000000-15-056371

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
December 3, 2015
Author
/s/Gary Todd for
Form
UPLOAD
Company
Sintx Technologies, Inc. (SINT) (CIK 0001269026)

Letter

Mail Stop 3030 December 3, 2015 Via E -mail Ty A. Lombardi Vice President Finance Amedica Corporation 1885 West 2100 South Salt Lake City, Utah 84119

Re: Amedica Corporation Form 10-K for Fiscal Year Ended December 31, 2014 Filed March 24 , 2015 File No. 001 -33624

Dear Mr. Lombardi :

We have limited our review of your filing s to the financial statements and related disclosures and have the following comment . In some of our comment s, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment 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 comment applies to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment , we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2014

Exhib its 31.1 and 31.2

1. We see that the officer certifications do not include the language referring to internal control over financial reporting that should appear in the introductory sentence of paragraph 4 and paragraph 4(b). Please amend the filing to incl ude the correct certifications. You may file an abbreviated amendment that includes a cover page, explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certification. Refer to Exchange Act Rule 13a -14(a) and Item 601(b)(31) of Regulation S -K. This comment also applies to your Forms 10 -Q for the quarters ended March 31, 2015, June 30, 2015 and September 30, 2015.

Ty A. Lombardi Amedica Corporation December 3, 2015 Page 2

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the f iling includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 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.

You may contact A ndri Boerman at (202) 551 -3645 or Gary Todd, Senior Accountant, at (202) 5 51-3605 with any questions. You may also reach me at (202) 551 -3676.

Sincerely,
/s/Gary Todd for

Show Raw Text
Mail Stop 3030
December 3, 2015

Via E -mail
Ty A. Lombardi
Vice President Finance
Amedica  Corporation
1885 West 2100 South
Salt Lake City, Utah   84119

Re: Amedica Corporation
Form 10-K for Fiscal Year Ended  December 31, 2014
Filed March 24 , 2015
File No. 001 -33624

Dear Mr. Lombardi :

We have limited our review of your filing s to the financial statements and related
disclosures and have the following comment .  In some of our comment s, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to this comment  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
comment applies  to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment , we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2014

Exhib its 31.1 and 31.2

1. We see that the officer certifications do not include the language referring to internal
control over financial reporting that should appear in the introductory sentence of
paragraph 4 and paragraph 4(b).  Please amend the filing to incl ude the correct
certifications.  You may file an abbreviated amendment that includes a cover page,
explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certification.  Refer
to Exchange Act Rule 13a -14(a) and Item 601(b)(31) of Regulation S -K.  This comment
also applies to your Forms 10 -Q for the quarters ended March 31, 2015, June 30, 2015
and September 30, 2015.

Ty A. Lombardi
Amedica  Corporation
December 3, 2015
Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the f iling includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 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.

You may contact A ndri Boerman at (202) 551 -3645 or Gary Todd, Senior Accountant, at
(202) 5 51-3605 with any questions.  You may also reach  me at (202) 551 -3676.

Sincerely,

 /s/Gary Todd  for

Brian Cascio
Accounting Branch Chief
Office of Electronics and Machinery