SEC Comment Letter for BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961) (BINI) — Jan 12, 2018
BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)
Date: Jan. 12, 2018 · CIK: 0001499961 · Accession: 0000000000-18-001335
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-222466
Letter
Mail Stop 4561 January 12, 2018 Jonathan New Chief Executive Officer Net Element , Inc. 3363 NE 163rd St., Suite 705 Miami, Florida, 3316 0
Re: Net Element , Inc. Registration Statement on Form S -3 Filed January 8, 2018 File No. 333-222466
Dear Mr. New:
We have limited our review of your registration statement to those issues we have addressed in our comment.
Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewi ng any amendment to your registration statement and the information you provi de in response to this comment , we may have additional comments.
Risk Factors
“We may not be able to develop new products or enhance the capabilities related to blockchain …,” page 4
1. You refer to new blockchain technology that is being developed by your blockchain business unit. Please expand your disclosure to provide a more specific description of your business unit , and discuss the effect of governmental regulations, if material . Refer to Item 101(h)(4)(iii) and (ix) of Regulation S -K. Please also tell us whether your blockchain technology business will involve holding or trading digital assets or cryptocurren cies.
Jonathan New Net Element , Inc. January 12 , 2018 Page 2
We remind you that the company and its management ar e responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Refer to Rule 461 regarding requests for acceleration. Please allow adequate time for us to review any am endment prior to the requested effective date of the registration statement.
Please contact Bernard Nolan, Staff Attorney , at (202) 551 -6515 with any questions. If you require further assistance, you may contact the undersigned at (202) 551 -3453.
Sincerely,
/s/ Jan Woo
Show Raw Text
Mail Stop 4561 January 12, 2018 Jonathan New Chief Executive Officer Net Element , Inc. 3363 NE 163rd St., Suite 705 Miami, Florida, 3316 0 Re: Net Element , Inc. Registration Statement on Form S -3 Filed January 8, 2018 File No. 333-222466 Dear Mr. New: We have limited our review of your registration statement to those issues we have addressed in our comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewi ng any amendment to your registration statement and the information you provi de in response to this comment , we may have additional comments. Risk Factors “We may not be able to develop new products or enhance the capabilities related to blockchain …,” page 4 1. You refer to new blockchain technology that is being developed by your blockchain business unit. Please expand your disclosure to provide a more specific description of your business unit , and discuss the effect of governmental regulations, if material . Refer to Item 101(h)(4)(iii) and (ix) of Regulation S -K. Please also tell us whether your blockchain technology business will involve holding or trading digital assets or cryptocurren cies. Jonathan New Net Element , Inc. January 12 , 2018 Page 2 We remind you that the company and its management ar e responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rule 461 regarding requests for acceleration. Please allow adequate time for us to review any am endment prior to the requested effective date of the registration statement. Please contact Bernard Nolan, Staff Attorney , at (202) 551 -6515 with any questions. If you require further assistance, you may contact the undersigned at (202) 551 -3453. Sincerely, /s/ Jan Woo Jan Woo Legal Branch Chief Office of Information Technologies and Services cc Serge Pavluk, Esq. Snell & Wilmer, Esq.