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SEC Comment Letter for BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961) (BINI) — Nov 25, 2013

BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)
Date: Nov. 25, 2013 · CIK: 0001499961 · Accession: 0000000000-13-064512

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-34887

Date
Nov. 25, 2013
Author
/s/ Maryse Mills -Apenteng
Form
UPLOAD
Company
BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)

Letter

November 22 , 2013 Via E-Mail Oleg Firer Chief Executive Officer Net Element International, Inc. 3363 NE 163rd Street, Suite 705 North Miami Beach, FL 33160

Re: Net Element International, Inc. Preliminary Merger Proxy Statement on Schedule 14A Filed September 2 7, 2013 File No. 001-34887

Dear Mr. Firer :

We have completed our review of your filings. We remind you that our comments or changes to disclosure in response to our comments do not foreclose 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 initiated by the Commission or any person under the federal secu rities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules re quire.

Sincerely,
/s/ Maryse Mills -Apenteng

Show Raw Text
November 22 , 2013

Via E-Mail
Oleg Firer
Chief Executive Officer
Net Element International, Inc.
3363 NE 163rd Street, Suite 705
North Miami Beach, FL 33160

Re: Net Element International, Inc.
  Preliminary Merger Proxy Statement on Schedule 14A
  Filed September 2 7, 2013
  File No. 001-34887

Dear Mr.  Firer :

We have completed our review of your filings.  We remind you that our comments or
changes to disclosure in response  to our comments do not foreclose 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 initiated by the Commission or any person under the
federal secu rities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filings to be certain that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules re quire.

Sincerely,

 /s/ Maryse Mills -Apenteng

Maryse Mills -Apenteng
Special Counsel

cc:  Via E -Mail
David Schubauer
Bilzin Sumberg  Baena Price & Axelrod LLP