SEC Comment Letter for VIVOS INC (RDGL) (CIK 0001449349) (RDGL) — Sep 26, 2019
VIVOS INC (RDGL) (CIK 0001449349)
Date: Sept. 26, 2019 · CIK: 0001449349 · Accession: 0000000000-19-014026
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 024-11049
Letter
September 26, 2019 Michael Korenko Chief Executive Officer Vivos Inc. 719 Jadwin Avenue Richland, Washington 99352 Re:Vivos Inc. Amendment No. 1 to Offering Statement on Form 1-A Filed September 9, 2019 File No. 024-11049 Dear Mr. Korenko: We have reviewed your amended offering statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe our comments apply 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 offering statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 23, 2019 letter. Amendment No. 1 to Offering Statement on Form 1-A filed September 9, 2019 Use of Proceeds, page 17 1.We note your response to prior comment 4. Please revise this section to disclose your intended use of proceeds assuming the sale of 25%, 50%, 75% and 100% of the offering, such as the estimated expenses of the offering and the amount to repay debt mentioned on page 17 and the commissions mentioned in Item 4 of Part I of the Form 1- A. Also, revise your disclosure to use the midpoint of the estimated price range for this offering.
FirstName LastNameMichael Korenko Comapany NameVivos Inc. September 26, 2019 Page 2 FirstName LastName Michael Korenko Vivos Inc. September 26, 2019 Page 2 Exhibits 2.We note your response to prior comment 9. Please file as an exhibit the subscription agreement. You may contact Gary Newberry at 202-551-3761 or Lynn Dicker, Senior Accountant, at 202-551-3616 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at 202-551-3602 or Amanda Ravitz, Assistant Director, at 202-551-3412 with any other questions. Sincerely, Division of Corporation Finance Office of Electronics and Machinery cc: Daniel W. Rumsey
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September 26, 2019
Michael Korenko
Chief Executive Officer
Vivos Inc.
719 Jadwin Avenue
Richland, Washington 99352
Re:Vivos Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed September 9, 2019
File No. 024-11049
Dear Mr. Korenko:
We have reviewed your amended offering statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe our comments apply 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 offering statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our August 23, 2019 letter.
Amendment No. 1 to Offering Statement on Form 1-A filed September 9, 2019
Use of Proceeds, page 17
1.We note your response to prior comment 4. Please revise this section to disclose
your intended use of proceeds assuming the sale of 25%, 50%, 75% and 100% of the
offering, such as the estimated expenses of the offering and the amount to repay debt
mentioned on page 17 and the commissions mentioned in Item 4 of Part I of the Form 1-
A. Also, revise your disclosure to use the midpoint of the estimated price range for this
offering.
FirstName LastNameMichael Korenko
Comapany NameVivos Inc.
September 26, 2019 Page 2
FirstName LastName
Michael Korenko
Vivos Inc.
September 26, 2019
Page 2
Exhibits
2.We note your response to prior comment 9. Please file as an exhibit the subscription
agreement.
You may contact Gary Newberry at 202-551-3761 or Lynn Dicker, Senior Accountant, at
202-551-3616 if you have questions regarding comments on the financial statements and related
matters. Please contact Thomas Jones at 202-551-3602 or Amanda Ravitz, Assistant Director, at
202-551-3412 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc: Daniel W. Rumsey