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SEC Comment Letter for Tonix Pharmaceuticals Holding Corp. (TNXP) (CIK 0001430306) (TNXP) — Apr 13, 2012

Tonix Pharmaceuticals Holding Corp. (TNXP) (CIK 0001430306)
Date: April 13, 2012 · CIK: 0001430306 · Accession: 0000000000-12-018978

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File numbers found in text: 333-150149

Date
April 13, 2012
Author
James Lopez
Form
UPLOAD
Company
Tonix Pharmaceuticals Holding Corp. (TNXP) (CIK 0001430306)

Letter

April 13, 2012 Via E-mail Seth Lederman President, Chief Executive Officer and Chairman Tonix Pharmaceuticals Holding Corp. 509 Madison Avenue, Suite 306 New York, New York 10022 Re: Tonix Pharmaceuticals Holding Corp. Current Report on Form 8-K Filed October 14, 2011 File No. 333-150149

Dear Mr. Lederman:

We have completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not fore close the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclo sure in the filing[s] to be certa in that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require.

S i n c e r e l y , / s / J a m e s L o p e z ( f o r ) John Reynolds Assistant Director cc: (via e-mail) Harvey Kesner, Esq. Sichenzia Ross Friedman Ference Anslow LLP

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April 13, 2012
  Via E-mail

Seth Lederman President, Chief Executive Officer and Chairman Tonix Pharmaceuticals Holding Corp. 509 Madison Avenue, Suite 306 New York, New York 10022
Re: Tonix Pharmaceuticals Holding Corp.
 Current Report on Form 8-K
Filed October 14, 2011                 File No. 333-150149

Dear Mr. Lederman:

We have completed our review of your f ilings.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not fore close the Commission from taking
any action with respect to the company or the filings and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclo sure in the filing[s] to be certa in that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules require.

     S i n c e r e l y ,
      / s /  J a m e s  L o p e z  ( f o r )        John Reynolds
Assistant Director
 cc: (via e-mail) Harvey Kesner, Esq.                          Sichenzia Ross Friedman Ference Anslow LLP