SEC Comment Letter for Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593) (XTNT) — Oct 27, 2016
Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593)
Date: Oct. 27, 2016 · CIK: 0001453593 · Accession: 0000000000-16-098738
AI Filing Summary & Sentiment
File numbers found in text: 333-213350
Letter
Mail Stop 4546 October 27 , 2016 John Gandolfo Chief Financial Officer Xtant Medical Holdings, Inc. 664 Cruiser Lane Belgrade, MT 59714
Re: Xtant Medical Holdings, Inc. Amendment No. 4 to Registration Statement on Form S -1 Filed October 21, 2016 File No. 333-213350
Dear Mr. Gandolf o:
We have reviewed your amended registration statement and have the following comment . 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 registration statement and providing the requested information . If you do not believe our comment appl ies to your facts and circumstances or do not be lieve 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 the comment, we may have additional comments.
Prospectus Cover
1. We ref er to your disclosure on page 3. Please revise the cover page to disclose the total number of subscription rights that you are distributing collectively to stockholders and noteholders in the offering .
John Gandolfo Xtant Medical Holdings, Inc. October 27, 2016 Page 2
Please contact Dorrie Yale at 202 -551-8776 or Jos eph McCann at 202 -551-6262 with any questions .
Sincerely,
/s/ Joseph McCann for
Show Raw Text
Mail Stop 4546 October 27 , 2016 John Gandolfo Chief Financial Officer Xtant Medical Holdings, Inc. 664 Cruiser Lane Belgrade, MT 59714 Re: Xtant Medical Holdings, Inc. Amendment No. 4 to Registration Statement on Form S -1 Filed October 21, 2016 File No. 333-213350 Dear Mr. Gandolf o: We have reviewed your amended registration statement and have the following comment . 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 registration statement and providing the requested information . If you do not believe our comment appl ies to your facts and circumstances or do not be lieve 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 the comment, we may have additional comments. Prospectus Cover 1. We ref er to your disclosure on page 3. Please revise the cover page to disclose the total number of subscription rights that you are distributing collectively to stockholders and noteholders in the offering . John Gandolfo Xtant Medical Holdings, Inc. October 27, 2016 Page 2 Please contact Dorrie Yale at 202 -551-8776 or Jos eph McCann at 202 -551-6262 with any questions . Sincerely, /s/ Joseph McCann for Suzanne Hayes Assistant Director Office of Insurance and Healthcare cc: Travis J. Leach, Esq. — Ballard Spahr LLP