SEC Comment Letter 0000000000-24-006450 to INVO Fertility, Inc. (IVF)
INVO Fertility, Inc.
Date: June 5, 2024 · CIK: 0001417926 · Accession: 0000000000-24-006450
AI Filing Summary & Sentiment
File numbers found in text: 333-279593
Letter
United States securities and exchange commission logo June 5, 2024 Steven Shum Chief Executive Officer INVO Bioscience, Inc. 5582 Broadcast Court Sarasota, Florida 34240 Re:INVO Bioscience, Inc. Registration Statement on Form S-3 Filed May 21, 2024 File No. 333-279593 Dear Steven Shum: We have conducted a limited review of your registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Registration Statement on Form S-3 Incorporation of Certain Documents by Reference, page 2 1.We note that you have incorporated by reference to your amended 10-Ks and 10-K for the year ended December 31, 2023. We note the disclosure in Note 9, on page F-14. Given the existence of notes payable, please clarify for us why you did not use your incremental borrowing rate in your lease accounting. See ASC 842-20-30-3. Also, please provide all of the disclosures required by ASC 842-20-50-4g.
FirstName LastNameSteven Shum Comapany NameINVO Bioscience, Inc. June 5, 2024 Page 2 FirstName LastName Steven Shum INVO Bioscience, Inc. June 5, 2024 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Marc Indeglia
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United States securities and exchange commission logo
June 5, 2024
Steven Shum
Chief Executive Officer
INVO Bioscience, Inc.
5582 Broadcast Court
Sarasota, Florida 34240
Re:INVO Bioscience, Inc.
Registration Statement on Form S-3
Filed May 21, 2024
File No. 333-279593
Dear Steven Shum:
We have conducted a limited review of your registration statement and have the
following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form S-3
Incorporation of Certain Documents by Reference, page 2
1.We note that you have incorporated by reference to your amended 10-Ks and 10-K for the
year ended December 31, 2023. We note the disclosure in Note 9, on page F-14. Given the
existence of notes payable, please clarify for us why you did not use your incremental
borrowing rate in your lease accounting. See ASC 842-20-30-3. Also, please provide all
of the disclosures required by ASC 842-20-50-4g.
FirstName LastNameSteven Shum
Comapany NameINVO Bioscience, Inc.
June 5, 2024 Page 2
FirstName LastName
Steven Shum
INVO Bioscience, Inc.
June 5, 2024
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545
with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc: Marc Indeglia