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SEC Comment Letter for ENvue Medical, Inc. (FEED) (CIK 0001326706) (FEED) — Jul 13, 2017

ENvue Medical, Inc. (FEED) (CIK 0001326706)
Date: July 13, 2017 · CIK: 0001326706 · Accession: 0000000000-17-024594

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File numbers found in text: 001-36445

Date
July 13, 2017
Author
/s/ Martin James
Form
UPLOAD
Company
ENvue Medical, Inc. (FEED) (CIK 0001326706)

Letter

Mail Stop 3030 July 13, 2017 Via E -mail Stephen Brown Chief Financial Officer NanoVibronix, Inc. 9 Derech Hashalom Street Nesher, Israel 36651

Re: NanoVibronix , Inc. Form 10 -K for the Fiscal Year Ended December 31 , 2016 Filed March 31, 2017 Form 10 -Q for the Quarterly Period Ended March 31, 2017 Filed May 15 , 2017 File No. 001-36445

Dear Mr. Brown :

We have limited our review of your filing to the financial statements and related disclosures and 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 business days b y providing the requested information or advise 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.

Form 10 -K for the Year Ended December 31, 2016

Consolidated Financial Statements

Consolidated Statements of Comprehensive Loss, page F -5

1. Revise this statement and other applicable sections of future filin gs to use parentheses to clearly show Operating loss, Loss before taxes on income, Net loss, and Total comprehensive loss as negative amounts, similar to your presentation s of the net loss per share amounts here and net loss in the statements of cash flows.

Stephen Brown NanoVibronix, Inc. July 13 , 2017 Page 2

Exhibits 31.1 and 31.2 Certifications Pursuant to Rule 13 -a-14(a)

2. On page 48, you correctly include Management’s Report on Internal Control over Financial Reporting as of December 31, 2016. Please amend the filing to provide currently dated certifications that ar e consistent with the language in Item 601(b)(31) of Regulation S -K, including the required language pertaining to your the internal control over financial reporting in the introduction to paragraph 4 and paragraph 4(b) in its entirety. This comment also a pplies to your Form 10 -Q for the period ended March 31, 2017.

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the st aff.

You may contact Dennis Hult at (202) 551 -3618, or me at (202) 551 -3671with any questions.

Sincerely,
/s/ Martin James

Show Raw Text
Mail Stop 3030
July 13, 2017

Via E -mail
Stephen Brown
Chief  Financial Officer
NanoVibronix, Inc.
9 Derech Hashalom Street
Nesher, Israel 36651

Re: NanoVibronix , Inc.
 Form 10 -K for the Fiscal Year Ended December 31 , 2016
 Filed March 31, 2017
 Form 10 -Q for the Quarterly Period Ended March 31, 2017
Filed May 15 , 2017
File No.  001-36445

Dear  Mr. Brown :

We have limited our review  of your filing  to the financial statements and related
disclosures and 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 business days b y providing the requested
information or advise 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.

Form 10 -K for the Year Ended December 31, 2016

Consolidated Financial Statements

Consolidated Statements of Comprehensive Loss, page F -5

1. Revise this statement and other applicable sections of future filin gs to use parentheses to
clearly show Operating loss, Loss before taxes on income, Net loss, and Total
comprehensive loss as negative amounts, similar to your presentation s of the net loss per
share amounts here and net loss in the statements of cash flows.

Stephen Brown
NanoVibronix, Inc.
July 13 , 2017
Page 2

 Exhibits 31.1 and 31.2 Certifications Pursuant to Rule 13 -a-14(a)

2. On page 48, you correctly include Management’s Report on Internal Control over
Financial Reporting as of December 31, 2016.  Please amend the filing to provide
currently dated certifications that ar e consistent with the language in Item 601(b)(31) of
Regulation S -K, including the required language pertaining to your the internal control
over financial reporting in the introduction to paragraph 4 and paragraph 4(b) in its
entirety. This comment also a pplies to your Form 10 -Q for the period ended March 31,
2017.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the st aff.

You may contact Dennis Hult at (202) 551 -3618, or me at (202) 551 -3671with any
questions.

Sincerely,

        /s/ Martin James

Martin J ames
Senior Assistant Chief Accountant
        Office of Electronics and Machinery