SEC Comment Letter for IGC Pharma, Inc. (IGC) (CIK 0001326205) (IGC) — Mar 13, 2015
IGC Pharma, Inc. (IGC) (CIK 0001326205)
Date: March 13, 2015 · CIK: 0001326205 · Accession: 0000000000-15-015049
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-201822
Letter
March 13, 2015 Mr. Ram Mukunda President and Chief Executive Officer India Globalization Capital, Inc. 4336 Montgomery Avenue Bethesda, Maryland 20814
Re: India Globalization Capital, Inc. Amendment No. 1 to Registration Statement on Form S-3 Filed March 3 , 2015 File No. 333-201822
Dear Mr. Mukunda :
We have limited our review of your registration statement to those issues we have addressed in our 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 this letter by amending your registration statement and providing the requested information . Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments , we may have additional comments.
Exhibit 5.1, Opinion of Olshan Frome Wolosky LLP
1. We note your response to comment 4. Please have counsel revise the legality opinion to opine separately on the units and on the warrants. See Section II.B.1.f and h of Staff Legal Bulletin No. 19 for guidance.
Mr. Ram Mukunda India Globalization Capital, Inc. March 13 , 2015 Page 2
Please contact Hillary Daniels at (202) 551 -3959 or Brigitte Lippmann at (202) 551 -3713 with any questions.
Sincerely,
/s/ Brigitte Lippmann (for)
Show Raw Text
March 13, 2015 Mr. Ram Mukunda President and Chief Executive Officer India Globalization Capital, Inc. 4336 Montgomery Avenue Bethesda, Maryland 20814 Re: India Globalization Capital, Inc. Amendment No. 1 to Registration Statement on Form S-3 Filed March 3 , 2015 File No. 333-201822 Dear Mr. Mukunda : We have limited our review of your registration statement to those issues we have addressed in our 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 this letter by amending your registration statement and providing the requested information . Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments , we may have additional comments. Exhibit 5.1, Opinion of Olshan Frome Wolosky LLP 1. We note your response to comment 4. Please have counsel revise the legality opinion to opine separately on the units and on the warrants. See Section II.B.1.f and h of Staff Legal Bulletin No. 19 for guidance. Mr. Ram Mukunda India Globalization Capital, Inc. March 13 , 2015 Page 2 Please contact Hillary Daniels at (202) 551 -3959 or Brigitte Lippmann at (202) 551 -3713 with any questions. Sincerely, /s/ Brigitte Lippmann (for) John Reynolds Assistant Director cc: Spencer G. Feldman, Esq. Olshan Frome Wolosky LLP