SEC Comment Letter for BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961) (BINI) — Oct 23, 2015

BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)
Date: Oct. 23, 2015 · CIK: 0001499961 · Accession: 0000000000-15-051102

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File numbers found in text: 001-34887

Date

October 21, 2015

Author

/s/ Maryse Mills -Apenteng

Form

UPLOAD

Company

BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)

Letter

Mail Stop 4561 October 21, 2015 Jonathan New Chief Financial Officer Net Element, Inc. 3363 NE 163rd Street, Suite 705 North Miami Beach, FL 33160

Re: Net Element, Inc. Preliminary Proxy Statement on Schedule 14 A Filed October 8, 2015 File No. 001-34887

Dear Mr. New :

We have completed our review of your filing. 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 filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We u rge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Maryse Mills -Apenteng

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Mail Stop 4561

October 21, 2015

Jonathan New
Chief Financial Officer
Net Element, Inc.
3363 NE 163rd Street, Suite 705
North Miami Beach, FL 33160

 Re: Net Element, Inc.
 Preliminary Proxy Statement on Schedule 14 A
 Filed October 8, 2015
 File No. 001-34887

Dear Mr. New :

We have completed our review of your filing.   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 filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.   We u rge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

        Sincerely,

        /s/ Maryse Mills -Apenteng

        Maryse Mills -Apenteng
        Special Counsel
        Office of Information  Technologies
and Services

cc: Serge V. Pavluk , Esq.
Snell & Wilmer L.L.P.

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