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SEC Comment Letter for Coda Octopus Group, Inc. (CODA) (CIK 0001334325) (CODA) — Sep 5, 2019

Coda Octopus Group, Inc. (CODA) (CIK 0001334325)
Date: Sept. 5, 2019 · CIK: 0001334325 · Accession: 0000000000-19-013223

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File numbers found in text: 333-233524

Date
September 5, 2019
Author
Annmarie Gayle
Form
UPLOAD
Company
Coda Octopus Group, Inc. (CODA) (CIK 0001334325)

Letter

September 5, 2019 Annmarie Gayle Chief Executive Officer Coda Octopus Group, Inc. 3300 S Hiawassee Rd., Suite 104-105 Orlando, Florida 32835 Re:Coda Octopus Group, Inc. Registration Statement on Form S-3 Filed August 29, 2019 File No. 333-233524 Dear Ms. Gayle: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 staff. Please contact Heather Clark at 202-551-3624 with any questions. Sincerely, Division of Corporation Finance Office of Transportation and Leisure

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September 5, 2019
Annmarie Gayle
Chief Executive Officer
Coda Octopus Group, Inc.
3300 S Hiawassee Rd., Suite 104-105
Orlando, Florida 32835
Re:Coda Octopus Group, Inc.
Registration Statement on Form S-3
Filed August 29, 2019
File No. 333-233524
Dear Ms. Gayle:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 staff.
            Please contact Heather Clark at 202-551-3624 with any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure