SEC Comment Letter for CREATIVE REALITIES, INC. (CREX) (CIK 0001356093) (CREX) — Jul 20, 2015
CREATIVE REALITIES, INC. (CREX) (CIK 0001356093)
Date: July 20, 2015 · CIK: 0001356093 · Accession: 0000000000-15-037552
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-201806
Letter
July 20 , 2015 John Walpuck Interim Chief Executive Officer and Chief Financial Officer Creative Realities, Inc. 55 Broadway , 9th Floor New York, New York 10006
Re: Creative Realities, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed July 9 , 2015 File No. 333-201806
Dear Mr. Walpuck :
We have reviewed your amended registration statement and have the following comment. In our comment, 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 . If you do not believe our comment appl ies 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 this comment, we may have additional comments.
Part II
Item 15. Recent Sales of Unregistered Securities, page II -2
1. You disclose here that you have conducted several unregistered issuances in 2015 i n reliance on Rule 506 of Regulation D. You have not, however, filed any Forms D in 2015. Please advise.
John Walpuck Creative Realities, Inc. July 20 , 2015 Page 2
You may contact Jeff Kauten, Attorney -Advisor, at (202) 551 -3447 , or in his absence, me at (202) 551 -3483 , with any questions. If you require further assistance, please contact Barbara C. Jacobs , Assistant Director, at (202) 551-3730.
Sincerely,
/s/ Katherine Wray
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July 20 , 2015 John Walpuck Interim Chief Executive Officer and Chief Financial Officer Creative Realities, Inc. 55 Broadway , 9th Floor New York, New York 10006 Re: Creative Realities, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed July 9 , 2015 File No. 333-201806 Dear Mr. Walpuck : We have reviewed your amended registration statement and have the following comment. In our comment, 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 . If you do not believe our comment appl ies 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 this comment, we may have additional comments. Part II Item 15. Recent Sales of Unregistered Securities, page II -2 1. You disclose here that you have conducted several unregistered issuances in 2015 i n reliance on Rule 506 of Regulation D. You have not, however, filed any Forms D in 2015. Please advise. John Walpuck Creative Realities, Inc. July 20 , 2015 Page 2 You may contact Jeff Kauten, Attorney -Advisor, at (202) 551 -3447 , or in his absence, me at (202) 551 -3483 , with any questions. If you require further assistance, please contact Barbara C. Jacobs , Assistant Director, at (202) 551-3730. Sincerely, /s/ Katherine Wray Katherine Wray Attorney -Advisor cc: Paul Chestovich, Esq. Maslon LLP