SEC Comment Letter for XWELL, Inc. (XWEL) (CIK 0001410428) (XWEL) — Mar 18, 2015
XWELL, Inc. (XWEL) (CIK 0001410428)
Date: March 18, 2015 · CIK: 0001410428 · Accession: 0000000000-15-016166
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March 18, 2015 Via Email Ms. Anastasia Nyrkovskaya Chief Financial Officer Vringo, Inc. 780 3rd Avenue, 12th Floor New York, NY 10017 Re: Vringo, Inc. Form 10 -K for the Fiscal Year Ended December 31, 2013 Filed March 1 0, 2014 File No. 001 -34785 Dear Ms. Nyrkovskaya : We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Robert S. Littlepage, for Larry Spirgel Assistant Director