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SEC Company Response from XWELL, Inc. (XWEL) (CIK 0001410428) (XWEL) — Dec 22, 2014

XWELL, Inc. (XWEL) (CIK 0001410428)
Date: Dec. 22, 2014 · CIK: 0001410428 · Accession: 0001144204-14-075305

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File numbers found in text: 001-34785

Referenced dates: December 19, 2014

Date
December 22, 2014
Author
/s/ Jeffrey Schultz
Form
CORRESP
Company
XWELL, Inc. (XWEL) (CIK 0001410428)

Letter

Jeffrey P. Schultz | 212 692 6732 | jschultz@mintz.com

One Financial Center

Boston, MA 02111

617-542-6000

617-542-2241 fax

www.mintz.com

December 22, 2014

VIA EDGAR SUBMISSION

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: William Mastrianna

Re: Vringo, Inc.

Form 10-K for Fiscal Year Ended December 31, 2013

Filed March 10, 2014

Form 10-Q for Fiscal Quarter Ended September 30, 2014

Filed November 4, 2014

File No. 001-34785

Ladies and Gentlemen:

On behalf of Vringo, Inc. (the “Company”), we are hereby filing with the Securities and Exchange Commission (the “Commission”) this letter in response to comments contained in the letter dated December 19, 2014 from Larry Spirgel of the Staff (the “Staff”) of the Commission to Anastasia Nyrkovskaya, the Company’s Chief Financial Officer. The Company has begun the process necessary to furnish the Staff with a response to its comment, but because of absences of certain individuals due to the holidays, the Company requires additional time to coordinate the needed input of various individuals, including members of the Company’s audit committee, senior management, and certain other employees, to finalize its response.

The Comment Letter requests that the Company respond to the comment within 10 business days (January 7, 2015) or tell the Staff the date by when the Company will provide its response. Based on a telephone conversation that we had with William Mastrianna on December 19, 2014, we hereby respectfully request on behalf of the Company an extension for the Company’s response of one week, or until January 14, 2015. Of course, if you have any questions regarding this letter, kindly contact the undersigned at (212) 692-6732. We appreciate the Staff’s consideration of this request.

Very truly yours,
/s/ Jeffrey Schultz

Show Raw Text
CORRESP
1
filename1.htm

        Jeffrey
        P. Schultz | 212 692 6732 | jschultz@mintz.com

        One Financial Center

        Boston, MA 02111

        617-542-6000

        617-542-2241 fax

        www.mintz.com

    December 22, 2014

VIA EDGAR SUBMISSION

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: William Mastrianna

 Re: Vringo, Inc.

Form 10-K for Fiscal Year Ended
December 31, 2013

Filed March 10, 2014

Form 10-Q for Fiscal Quarter
Ended September 30, 2014

Filed November 4, 2014

File No. 001-34785

Ladies and Gentlemen:

On
behalf of Vringo, Inc. (the “Company”), we are hereby filing with the Securities and Exchange Commission (the
“Commission”) this letter in response to comments contained in the letter dated December 19, 2014 from Larry
Spirgel of the Staff (the “Staff”) of the Commission to Anastasia Nyrkovskaya, the Company’s Chief Financial
Officer. The Company has begun the process necessary to furnish the Staff with a response to its comment, but because of absences
of certain individuals due to the holidays, the Company requires additional time to coordinate the needed input of various individuals,
including members of the Company’s audit committee, senior management, and certain other employees, to finalize its response.

The
Comment Letter requests that the Company respond to the comment within 10 business days (January 7, 2015) or tell the Staff the
date by when the Company will provide its response. Based on a telephone conversation that we had with William Mastrianna on December
19, 2014, we hereby respectfully request on behalf of the Company an extension for the Company’s response of one week, or
until January 14, 2015. Of course, if you have any questions regarding this letter, kindly contact the undersigned at (212) 692-6732.
We appreciate the Staff’s consideration of this request.

    Very truly yours,

    /s/ Jeffrey Schultz

    Jeffrey P. Schultz

 cc: Securities and Exchange Commission

Larry Spirgel

Vringo, Inc.

Anastasia Nyrkovskaya,
Chief Financial Officer

Mintz, Levin, Cohn,
Ferris, Glovsky and Popeo, P.C.

Kenneth Koch, Esq.

Mintz,
Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

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