SEC Company Response from Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083) (SNOA) — Feb 18, 2011
Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)
Date: Feb. 18, 2011 · CIK: 0001367083 · Accession: 0001144204-11-009892
AI Filing Summary & Sentiment
File numbers found in text: 001-33216, 333-171411
Referenced dates: January 13, 2011
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Unassociated Document
February
18, 2011
Ms.
Aslynn Hogue
United
States Securities and Exchange Commission
Division
of Corporate Finance
100 F
Street, N.E.
Washington,
DC 20549
Re:
Oculus
Innovative Sciences, Inc.
Registration Statement on Form
S-3
Filed December 23, 2010
File No.
333-171411
Dear Ms.
Hogue:
I am
securities counsel for Oculus Innovative Sciences, Inc. (the
“Company”). Set forth below is the Company’s response to comments
received from the staff of the Securities and Exchange Commission (the “Staff”)
in their letter dated January 13, 2011. The numbering of the response
corresponds to the numbering of the comment in the letter from the
Staff. Furthermore, today we are filing Amendment 1 to the Form
S-3. The purpose of the Amendment is to add our legal
opinion. We have also made other non-substantive revisions, including
changing certain dates in the Form S-3.
Comment
1:
We
note the comments on your Form 10-K for the fiscal year ended March 31,
2010 that were issued on January 13, 2011. Please confirm that you will
resolve any comments on your Form 10-K before requesting acceleration of
the effective date of this registration
statement.
Response
1:
We
note the Staff’s comment. From a phone conversation with the Staff on
February 11, 2011, we understand from the Staff that there are no further
comments on the Form 10-K.
Please
contact me if you have any questions, we are happy to cooperate in any way we
can.
Regards,
/s/ Amy M.
Trombly
Amy M.
Trombly, Esq.
February
18, 2011
United
States Securities and Exchange Commission
Division
of Corporate Finance
100 F
Street, N.E., Mail Stop 3030
Washington,
D.C. 20549
Attn:
Aslynn
Hogue
Re:
Oculus
Innovative Sciences, Inc.
Registration Statement on Form
S-3
Filed December 23, 2010
File No. 333-171411
Form 10-K for the fiscal year ended
March 31, 2010
Filed June 8, 2010
File No. 001-33216
Dear Ms.
Hogue:
In
response to comments received from the staff of the Securities and Exchange
Commission (the “Staff”) on the Registration Statement on Form S-3 filed on
December 23, 2010, the undersigned, being the Chief Executive Officer of Oculus
Innovative Sciences, Inc., hereby acknowledges the following:
·
should
the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from
taking any action with respect to the
filing;
·
the
action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve Oculus
Innovative Sciences, Inc. from its full responsibility for the adequacy
and accuracy of the disclosure in the filing;
and
·
Oculus
Innovative Sciences, Inc. acknowledges that it may not assert Staff
comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United
States.
In
response to comments received from the Staff on the Form 10-K for the fiscal
year ended March 31, 2010 filed on June 8, 2010, the undersigned, being the
Chief Executive Officer of Oculus Innovative Sciences, Inc., hereby acknowledges
that:
·
Oculus
Innovative Sciences, Inc. is responsible for the adequacy and accuracy of
the disclosure in the filing;
·
Staff
comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the
filing; and
·
Oculus
Innovative Sciences, Inc. may not assert Staff comments as a defense in
any proceeding initiated by the Commission or any person under the federal
securities laws of the United
States.
Please do
not hesitate to contact Amy Trombly, Esq. at (617) 243-0060 if you need anything
further.
/s/
Hojabr Alimi
Hojabr
Alimi
Chief
Executive Officer