SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Company Response from CREATIVE REALITIES, INC. (CREX) (CIK 0001356093) (CREX) — Oct 22, 2018

CREATIVE REALITIES, INC. (CREX) (CIK 0001356093)
Date: Oct. 22, 2018 · CIK: 0001356093 · Accession: 0001213900-18-014237

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-225876

Referenced dates: September 28, 2018

Date
October 22, 2018
Author
/s/ Will Logan
Form
CORRESP
Company
CREATIVE REALITIES, INC. (CREX) (CIK 0001356093)

Letter

United States Securities and Exchange Commission Re: Creative Realities, Inc. (the “Company”) Amendment No. 2 to Registration Statement on Form S-1 Filed on September 21, 2018 File No. 333-225876

Dear Mr. Foland:

Thank you for your comment letter dated September 28, 2018. With this response letter we are filing Amendment No. 3 to the above-referenced registration statement (the “Amendment”). To facilitate your review of the Amendment, below please find our responses to your comments, together with the text of your original comments.

Amendment No. 2 to Form S-1

Prospectus Summary, page 1

1. Please clarify whether the closing of this offering is a condition to the acquisition of Allure Global Solutions, Inc. If so, include disclosure that the acquisition may not occur if you are not approved for listing on The NASDAQ Capital Market, which is a condition of this offering.

RESPONSE: In the Amendment, we have revised the Prospectus Summary section to include clear disclosure that the closing of the offering is a condition to the closing of our acquisition of Allure Global Solutions, and that the acquisition may not occur if we are not approved for listing on The NASDAQ Capital Market, which is a condition of the offering.

General

2. Instruction 1 to Signatures of Form S-1 requires signatures of your principal executive officer or officers, your principal financial officer, your controller or principal accounting officer and at least a majority of the board of directors or persons performing similar functions. To the extent that you are signing in more than one capacity, indicate each capacity in which you are signing. Please revise.

RESPONSE: In the Amendment, we have reviewed and revised the signature page to ensure that each capacity in which a person is signing the registration statement is indicated thereon.

Thank you for your attention to our Amendment. Should have any questions or additional comments, please feel free to contact the undersigned, Mr. Richard Mills, or Mr. Bradley Pederson, Esq. of Maslon LLP.

Sincerely,
/s/ Will Logan

Show Raw Text
CORRESP
1
filename1.htm

Creative Realities, Inc.

13100 Magisterial Drive, Suite 100

Louisville, Kentucky 40223

October  22, 2018

TRANSMITTED VIA EDGAR

Mr. Michael Foland, Attorney-Advisor

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: Creative Realities, Inc. (the “Company”)

Amendment No. 2 to Registration Statement
on Form S-1

Filed on September 21, 2018

File No. 333-225876

Dear Mr. Foland:

Thank you for your comment letter dated September 28, 2018.
With this response letter we are filing Amendment No. 3 to the above-referenced registration statement (the “Amendment”).
To facilitate your review of the Amendment, below please find our responses to your comments, together with the text of your original
comments.

Amendment No. 2 to Form S-1

Prospectus Summary, page 1

1. Please clarify whether the closing of this offering is a condition to the acquisition of Allure Global Solutions, Inc. If
so, include disclosure that the acquisition may not occur if you are not approved for listing on The NASDAQ Capital Market, which
is a condition of this offering.

RESPONSE: In the Amendment, we have revised the Prospectus Summary
section to include clear disclosure that the closing of the offering is a condition to the closing of our acquisition of Allure
Global Solutions, and that the acquisition may not occur if we are not approved for listing on The NASDAQ Capital Market, which
is a condition of the offering.

General

2. Instruction 1 to Signatures of Form S-1 requires signatures of your principal executive officer or officers, your principal
financial officer, your controller or principal accounting officer and at least a majority of the board of directors or persons
performing similar functions. To the extent that you are signing in more than one capacity, indicate each capacity in which you
are signing. Please revise.

RESPONSE: In the Amendment, we have reviewed and revised the
signature page to ensure that each capacity in which a person is signing the registration statement is indicated thereon.

Thank you for your attention to our Amendment. Should have any
questions or additional comments, please feel free to contact the undersigned, Mr. Richard Mills, or Mr. Bradley Pederson, Esq.
of Maslon LLP.

Sincerely,

/s/ Will Logan

Will Logan

Chief Financial Officer