SEC Comment Letter for ClearPoint Neuro, Inc. (CLPT) (CIK 0001285550) (CLPT) — Aug 18, 2016
ClearPoint Neuro, Inc. (CLPT) (CIK 0001285550)
Date: Aug. 18, 2016 · CIK: 0001285550 · Accession: 0000000000-16-089207
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-54575
Letter
Mail Stop 3030 August 18 , 2016 Harold A. Hurwitz Chief Financial Officer MRI Interventions, Inc. 5 Musick Irvine, California 92618
Re: MRI Interventions, Inc. Form 10-K for the fiscal year ended December 31, 2015 Filed March 25, 2016 File No. 000-54575
Dear Mr. Hurwitz :
We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
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 your response.
After reviewing your response to these comments, we may have additional comments.
Results of Operations, page 44
1. We note that your reusable product revenues appear to have increased significantly in fiscal year 2015 compared to fiscal year 2014. Please revise future filings to disclose the extent to which changes in revenue are attributable to changes in prices or to changes in the volume or amount of goods or services being sold. Refer to Item 303(a )(3)(iii) of Regulation S -K.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing 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.
Harold A. Hurwitz MRI Interventions, Inc. August 1 8, 2016 Page 2
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.
Please contact Heather Percival at (202) 551 -3498 or Tim Buchmiller, Senior Attorney, at (202) 551 -3635 with any questions.
Sincerely,
/s/ Tim Buchmiller for
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Mail Stop 3030 August 18 , 2016 Harold A. Hurwitz Chief Financial Officer MRI Interventions, Inc. 5 Musick Irvine, California 92618 Re: MRI Interventions, Inc. Form 10-K for the fiscal year ended December 31, 2015 Filed March 25, 2016 File No. 000-54575 Dear Mr. Hurwitz : We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. 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 your response. After reviewing your response to these comments, we may have additional comments. Results of Operations, page 44 1. We note that your reusable product revenues appear to have increased significantly in fiscal year 2015 compared to fiscal year 2014. Please revise future filings to disclose the extent to which changes in revenue are attributable to changes in prices or to changes in the volume or amount of goods or services being sold. Refer to Item 303(a )(3)(iii) of Regulation S -K. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing 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. Harold A. Hurwitz MRI Interventions, Inc. August 1 8, 2016 Page 2 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. Please contact Heather Percival at (202) 551 -3498 or Tim Buchmiller, Senior Attorney, at (202) 551 -3635 with any questions. Sincerely, /s/ Tim Buchmiller for Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Richard Mattern , Esq. Bass Berry & Sims PLC