SEC Company Response from IGC Pharma, Inc. (IGC) (CIK 0001326205) (IGC) — Mar 15, 2006
IGC Pharma, Inc. (IGC) (CIK 0001326205)
Date: March 15, 2006 · CIK: 0001326205 · Accession: 0000950137-06-003061
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-124942
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Re: India Globalization Capital, Inc. Amendment No. 5 to the Registration Statement on Form S-1 Registration Statement No. 333-124942
Dear Mr. Reynolds:
India Globalization Capital, Inc. (the “Company”) has filed with the Commission an Amendment No. 5 to the above referenced Registration Statement. For your convenience, we are providing you with five paper copies of Amendment No. 5 marked to show the changes made from Amendment No. 4 to the Registration Statement which was filed with the Commission on August 19, 2005. The changes reflected in Amendment No. 5 are as follows:
1. The Registration Statement has been revised to reflect the downsizing of the offering from $120,000,000 to $60,000,000.
2. Since the filing of Amendment No. 4, Raghu Ram, formerly Executive Vice President of the Company, resigned and the Company repurchased his 125,000 shares of common stock. The prospectus has been revised accordingly.
3. The Company now proposes to list its securities on the American Stock Exchange. The prospectus, including the risk factors section, has been revised to reflect that change.
4. Since the filing of Amendment No. 4, Ranga Krishna has loaned the Company a total of $50,000. The prospectus has been revised to disclose that loan.
5. The risk factors have been updated.
Securities and Exchange Commission
Attn: John Reynolds
November 2, 2005
Page 2
6. The Warrant Purchase Agreement and the prospectus disclosure have been amended to incorporate the comments of the Division of Market Regulation regarding Regulation M as reflected in the no-action letter relating to Key Hospitality Acquisition Corporation.
7. New audited financial statements as at September 30, 2005 have been included.
If you have any questions with respect to this letter, please contact me at (312) 269-8962.
Very truly yours,
SEYFARTH SHAW LLP
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CORRESP
1
filename1.htm
corresp
(312) 269-8962
mblount@seyfarth.com
November 2, 2005
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn:
John Reynolds
Assistant Director
Division of Corporation Finance
Re:
India Globalization Capital, Inc.
Amendment No. 5 to the Registration Statement on Form S-1
Registration Statement No. 333-124942
Dear Mr. Reynolds:
India Globalization Capital, Inc. (the “Company”) has filed with the Commission an Amendment
No. 5 to the above referenced Registration Statement. For your convenience, we are providing you
with five paper copies of Amendment No. 5 marked to show the changes made from Amendment No. 4 to
the Registration Statement which was filed with the Commission on August 19, 2005. The changes
reflected in Amendment No. 5 are as follows:
1. The Registration Statement has been revised to reflect the downsizing of the offering from
$120,000,000 to $60,000,000.
2. Since the filing of Amendment No. 4, Raghu Ram, formerly Executive Vice President of the
Company, resigned and the Company repurchased his 125,000 shares of common stock. The prospectus
has been revised accordingly.
3. The Company now proposes to list its securities on the American Stock Exchange. The
prospectus, including the risk factors section, has been revised to reflect that change.
4. Since the filing of Amendment No. 4, Ranga Krishna has loaned the Company a total of
$50,000. The prospectus has been revised to disclose that loan.
5. The risk factors have been updated.
Securities and Exchange Commission
Attn: John Reynolds
November 2, 2005
Page 2
6. The Warrant Purchase Agreement and the prospectus disclosure have been amended to
incorporate the comments of the Division of Market Regulation regarding Regulation M as reflected
in the no-action letter relating to Key Hospitality Acquisition Corporation.
7. New audited financial statements as at September 30, 2005 have been included.
If you have any questions with respect to this letter, please contact me at (312) 269-8962.
Very truly yours,
SEYFARTH SHAW LLP
/s/ Michael E. Blount
Michael E. Blount
MEB:tbm
cc:
Thomas Kluck
Mike Karney
Maureen Bauer
Terence O’Brien
Ram Mukunda
John Cherin
Stanley Jutkowitz
Jay Kaplowitz
Kristen Angelino