SEC Comment Letter for AYTU BIOPHARMA, INC (AYTU) (CIK 0001385818) (AYTU) — Apr 10, 2007
AYTU BIOPHARMA, INC (AYTU) (CIK 0001385818)
Date: April 10, 2007 · CIK: 0001385818 · Accession: 0000000000-07-017602
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-139933
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 April 10, 2007 Mr. James B. Wiegand President Rosewind Corporation 16200 WCR 18E Loveland, CO 80537
Re: Rosewind Corporation Amendment No. 2 to Registrati on Statement on Form SB-2 Filed March 30, 2007 File No. 333-139933
Dear Mr. Wiegand:
We have reviewed your amended filing a nd have the following comments. Where indicated, we think you should re vise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the ove rall disclosure in your filing. We look forward to working with you in these re spects. We welcome any questions you may have about our comments or any other aspect of our re view. Feel free to call us at the telephone numbers listed at the end of this letter.
Risk Factors, page 7 and Desc ription of Business, page 19 1. We note your added disclosure in response to prior comment 9. However, your added disclosure implying that you have not yet i nvestigated any licens ing or certification requirements appears inconsistent with your disclosure under “Government Regulation” on page 21 which indicates that you “are not subject to governmental regulation beyond the documentation of [your] vessel and registration of its radio.” Please clarify whether you are subject to governmental regulation and, if so, how you intend on complying.
Mr. James B. Wiegand Rosewind Corporation April 10, 2007 p. 2
Management’s Discussion and Analysis or Plan of Operations, page 24 2. We note your supplemental responses to prior comment 10. Revise your “plan of operations” subsection to include your supplemental responses.
Exhibits 3. File a legality opinion covering the shares being sold in the offering.
* * *
As appropriate, please amend your filing in resp onse to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your res ponses to our comments a nd provides any requested information. Detailed cover lette rs greatly facilitate our review . Please understand that we may have additional comments after reviewing your amendments and responses to our comments. We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement. Please a llow adequate time after the fili ng of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
You may contact William Bennett, Staff Attorney, at (202) 551-3389, or me, at 202-551- 3810, with any other questions.
S i n c e r e l y ,
L a r r y S p i r g e l A s s i s t a n t D i r e c t o r
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
April 10, 2007
Mr. James B. Wiegand
President
Rosewind Corporation
16200 WCR 18E
Loveland, CO 80537
Re: Rosewind Corporation
Amendment No. 2 to Registrati on Statement on Form SB-2
Filed March 30, 2007
File No. 333-139933
Dear Mr. Wiegand:
We have reviewed your amended filing a nd have the following comments. Where
indicated, we think you should re vise your document in response to these comments. If you
disagree, we will consider your explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we
may ask you to provide us with information so we may better understand your disclosure. After
reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance
with the applicable disclosure requirements and to enhance the ove rall disclosure in your filing.
We look forward to working with you in these re spects. We welcome any questions you may have
about our comments or any other aspect of our re view. Feel free to call us at the telephone
numbers listed at the end of this letter.
Risk Factors, page 7 and Desc ription of Business, page 19
1. We note your added disclosure in response to prior comment 9. However, your added
disclosure implying that you have not yet i nvestigated any licens ing or certification
requirements appears inconsistent with your disclosure under “Government Regulation” on
page 21 which indicates that you “are not subject to governmental regulation beyond the documentation of [your] vessel and registration of its radio.” Please clarify whether you are
subject to governmental regulation and, if so, how you intend on complying.
Mr. James B. Wiegand
Rosewind Corporation
April 10, 2007 p. 2
Management’s Discussion and Analysis or Plan of Operations, page 24
2. We note your supplemental responses to prior comment 10. Revise your “plan of
operations” subsection to include your supplemental responses.
Exhibits
3. File a legality opinion covering the shares being sold in the offering.
* * *
As appropriate, please amend your filing in resp onse to these comments. You may wish to
provide us with marked copies of the amendment to expedite our review. Please furnish a cover
letter with your amendment that keys your res ponses to our comments a nd provides any requested
information. Detailed cover lette rs greatly facilitate our review . Please understand that we may
have additional comments after reviewing your amendments and responses to our comments.
We direct your attention to Rules 460 and 461 regarding requesting acceleration of a
registration statement. Please a llow adequate time after the fili ng of any amendment for further
review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
You may contact William Bennett, Staff Attorney, at (202) 551-3389, or me, at 202-551-
3810, with any other questions.
S i n c e r e l y ,
L a r r y S p i r g e l
A s s i s t a n t D i r e c t o r