SEC Comment Letter for Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593) (XTNT) — Sep 22, 2009
Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593)
Date: Sept. 22, 2009 · CIK: 0001453593 · Accession: 0000000000-09-052860
AI Filing Summary & Sentiment
File numbers found in text: 333-158426
Referenced dates: August 28, 2009
Letter
Mail Stop 3561 September 22, 2009 Jennifer H. Jarvis President and Chief Executive Officer K-Kitz, Inc. 1630 Integrity Drive East Columbus, OH 43209 Re: K-Kitz, Inc. Amendment No. 3 to Registrati on Statement on Form S-1 Filed September 18, 2009 File No. 333-158426
Dear Mr. Jarvis:
We have reviewed your filing and have the following comments. Where indicated, we think you should re vise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments.
Dilution of the Price You Pay For Your Shares, page 11
1. We have reviewed your response to prior comment 1 in our letter dated August 28, 2009. Please revise your pre-offering net tangible book value amounts under each offering scenario to read $69,066, which represents your shareholder’s equity balance as of June 30, 2009. Although your post-offering net tangible book value amounts appear to be appropriately calculated, the adjustments to your pre-offering net tangible book value figures will result in chan ges to the amounts presented in the “Net tangible book value per share before offering” and “Increase in net tangible book value per share attributab le to new investors” line items.
Jennifer H. Jarvis K-Kitz, Inc. September 22, 2009 Page 2 Financial Statements
Note 9. Restatement of December 31, 2008 Financial Statements, page F-13
2. We have reviewed your response to prior comment 3 in our letter dated August 28, 2009. Please ensure that your restatem ent footnote includes a table showing the changes made to the individual line items on your statements of operations.
****
As appropriate, please amend your regist ration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cove r letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments. You may contact Andrew Blume, Acc ountant, at (202) 551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg, Staff Attorney, at (202) 551-3342, or Mara Ransom, Legal Branch Chief, or me at (202) 551-3720 with any other questions. S i n c e r e l y , H. Christopher Owings Assistant Director cc: Spencer G. Feldman, Esq. Greenberg Traurig, LLP
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Mail Stop 3561
September 22, 2009
Jennifer H. Jarvis President and Chief Executive Officer K-Kitz, Inc. 1630 Integrity Drive East Columbus, OH 43209
Re: K-Kitz, Inc.
Amendment No. 3 to Registrati on Statement on Form S-1
Filed September 18, 2009
File No. 333-158426
Dear Mr. Jarvis:
We have reviewed your filing and have the following comments. Where
indicated, we think you should re vise your document in response to these comments. If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary. Please be as deta iled as necessary in your explanation. In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure. After reviewing th is information, we may raise additional
comments.
Dilution of the Price You Pay For Your Shares, page 11
1. We have reviewed your response to prior comment 1 in our letter dated August
28, 2009. Please revise your pre-offering net tangible book value amounts under each offering scenario to read $69,066, which represents your shareholder’s equity balance as of June 30, 2009. Although your post-offering net tangible
book value amounts appear to be appropriately calculated, the adjustments to your pre-offering net tangible book value figures will result in chan ges to the amounts
presented in the “Net tangible book value per share before offering” and “Increase
in net tangible book value per share attributab le to new investors” line items.
Jennifer H. Jarvis
K-Kitz, Inc. September 22, 2009 Page 2 Financial Statements
Note 9. Restatement of December 31, 2008 Financial Statements, page F-13
2. We have reviewed your response to prior comment 3 in our letter dated August
28, 2009. Please ensure that your restatem ent footnote includes a table showing
the changes made to the individual line items on your statements of operations.
****
As appropriate, please amend your regist ration statement in response to these
comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information. Detailed cover
letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
You may contact Andrew Blume, Acc ountant, at (202) 551-3254 if you have
questions regarding comments on the financial statements and related matters. Please
contact Scott Anderegg, Staff Attorney, at (202) 551-3342, or Mara Ransom, Legal
Branch Chief, or me at (202) 551-3720 with any other questions.
S i n c e r e l y , H. Christopher Owings
Assistant Director
cc: Spencer G. Feldman, Esq.
Greenberg Traurig, LLP