SEC Company Response from SmartMetric, Inc. (SMME) (CIK 0001301991) — Mar 21, 2022
SmartMetric, Inc. (SMME) (CIK 0001301991)
Date: March 21, 2022 · CIK: 0001301991 · Accession: 0001829126-22-006416
AI Filing Summary & Sentiment
File numbers found in text: 000-54853
Referenced dates: February 18, 2022
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance John Cash Senior, Accounting Branch Chief Re: SmartMetric, Inc. Form 10-K for the Fiscal Year Ended June 30, 2021 File No. 000-54853
Dear Mr. Welcome and Mr. Cash:
This letter is written in response to the letter dated February 18, 2022 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), to Smartmetric, Inc. (“Smartmetric”, “we,” “us,” or “our”) relating to the above referenced filings. For your ease of reference, the Staff’s comments are repeated below in italicized font, and each comment is followed by our response.
Form 10-K for the Fiscal Year Ended June 30, 2021
Item 9A. Controls and Procedures
Management's Annual Report on Internal Control Over Financial Reporting, page 26
1. We note your responses to prior comments one and two. Please revise future annual filings to provide the appropriate language and assessment regarding your internal control over financial reporting. Refer to Item 308(a)(3) of Regulation S-K..
Response: As we previously noted for the Staff, due to a scrivener’s error, we inadvertently misstated our management’s conclusion regarding internal controls over financial reporting in our Form 10-K for the fiscal year ended June 30, 2021. Concurrently with the filing of this response letter, we will file an amendment to our Form 10-K for the fiscal year ended June 30, 2021 to correct this scrivener’s error.
Please direct any further comments or questions to me at (305) 607-3910.
Sincerely,
/s/ Chaya Coleena Hendrick
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SMARTMETRIC, INC.
3960 Howard Hughes Parkway, Suite 500
Las Vegas, NV 89109
March 18, 2022
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn.: Dale Welcome, Senior Accountant;
John Cash Senior, Accounting Branch Chief
Re: SmartMetric, Inc.
Form 10-K for the Fiscal Year Ended
June 30, 2021
File No. 000-54853
Dear Mr. Welcome and Mr. Cash:
This letter is written in response to the letter
dated February 18, 2022 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
to Smartmetric, Inc. (“Smartmetric”, “we,” “us,” or “our”) relating to the above referenced
filings. For your ease of reference, the Staff’s comments are repeated below in italicized font, and each comment is followed by
our response.
Form 10-K for the Fiscal Year Ended June 30, 2021
Item 9A. Controls and Procedures
Management's Annual Report on Internal Control Over Financial Reporting,
page 26
1. We note your responses to prior comments one and two. Please revise future annual filings to provide
the appropriate language and assessment regarding your internal control over financial reporting. Refer to Item 308(a)(3) of Regulation
S-K..
Response: As we previously noted
for the Staff, due to a scrivener’s error, we inadvertently misstated our management’s conclusion regarding internal controls
over financial reporting in our Form 10-K for the fiscal year ended June 30, 2021. Concurrently with the filing of this response letter,
we will file an amendment to our Form 10-K for the fiscal year ended June 30, 2021 to correct this scrivener’s error.
Please direct any further comments or questions to me at (305) 607-3910.
Sincerely,
/s/ Chaya Coleena Hendrick
Chaya C. Hendrick
Founder and CEO
Smartmetric, Inc.
cc: Andrea Cataneo, Esq., Mitchell Silberberg & Knupp LLP
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