SEC Company Response from Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083) (SNOA) — Jul 24, 2009
Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)
Date: July 24, 2009 · CIK: 0001367083 · Accession: 0000950123-09-025076
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File numbers found in text: 333-158539
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CORRESP
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CORRESPONDENCE
[Company Letterhead]
July 24, 2009
VIA FACSIMILE TO (703) 813-6985 AND EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 3030
Washington, DC 20549
Attention: Geoffrey Kruczek
Re:
Oculus Innovative Sciences, Inc.
File No. 333-158539
Dear Mr. Kruczek:
Pursuant to Rule 461 of the Rules and Regulations promulgated under the Securities Act of 1933, as
amended, the undersigned, as the placement agent of units as described in the
above-captioned Registration Statement on Form S-1 (the “Registration Statement”), hereby join in
the request of Oculus Innovative Sciences, Inc. that the effectiveness of the Registration
Statement be accelerated to July 24, 2009 at 4:30 pm EST or as soon as practicable thereafter.
In connection with this acceleration request and pursuant to Rule 460 of the Securities Act, the
following information is provided with respect to the distribution to date, of the preliminary
prospectus dated July 21, 2009:
Number of
To Whom Distributed
Copies
Underwriters
—
Institutional Investors
46
Individuals
562
Other Broker-Dealers
1,028
Total
1,636
With respect to Rule 15c2-8 under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), the undersigned has distributed or will distribute copies of the preliminary prospectus at
least 48 hours prior to the date confirmations of sale are expected to be mailed. In addition,
each underwriter and each selected dealer, if any, will represent to the undersigned that it has
and will comply with Rule 15c2-8 under the Exchange Act.
Very truly yours,
DAWSON JAMES SECURITIES, INC.
/s/ Albert Poliak
By: Albert Poliak, President