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SEC Company Response from BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961) (BINI) — Sep 17, 2014

BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)
Date: Sept. 17, 2014 · CIK: 0001499961 · Accession: 0001144204-14-056467

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File numbers found in text: 333-182076

Date
September 17, 2014
Author
/s/ Jonathan New
Form
CORRESP
Company
BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)

Letter

VIA EDGAR Post-Effective Amendment No. 7 on Form S-3 to Registration Statement on Form S-4 File No. 333-182076

Re: Net Element, Inc.

Dear Sir or Madam:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Net Element, Inc. (the “Company”) hereby requests that the effective date of the above-referenced Post-Effective Amendment No. 7 be accelerated so that the Post-Effective Amendment No. 7 may become effective on Friday, September 19, 2014, at 4:00 p.m (Washington D.C. time), or as soon thereafter as may be practicable.

The Company acknowledges that:

· should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

· the action of the Commission or the staff, acting pursuant to delegated authority in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

· the Company may not assert staff comments and the declaration of the effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Company confirms that it is aware of its responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the above-referenced Post-Effective Amendment No. 7.

We request that we be notified of such effectiveness by a telephone call to Serge V. Pavluk, of Snell & Wilmer L.L.P. at (714) 427-7442.

Sincerely,
/s/ Jonathan New

Show Raw Text
CORRESP
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filename1.htm

September 17, 2014

VIA EDGAR

U.S. Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

 Re: Net Element, Inc.

Post-Effective
Amendment No. 7 on Form S-3

to
Registration Statement on Form S-4

File
No. 333-182076

Dear Sir or Madam:

Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Net Element, Inc. (the “Company”)
hereby requests that the effective date of the above-referenced Post-Effective Amendment No. 7 be accelerated so that the Post-Effective
Amendment No. 7 may become effective on Friday, September 19, 2014, at 4:00 p.m (Washington D.C. time), or as soon thereafter as may be practicable.

The Company acknowledges
that:

 · should the Securities and Exchange Commission (the
“Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing;

 · the action of the Commission or the staff, acting pursuant
to delegated authority in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and

 · the Company may not assert staff comments and the declaration
of the effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws
of the United States.

The Company confirms
that it is aware of its responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, as they
relate to the proposed offering of the securities specified in the above-referenced Post-Effective Amendment No. 7.

We request that we
be notified of such effectiveness by a telephone call to Serge V. Pavluk, of Snell & Wilmer L.L.P. at (714) 427-7442.

Sincerely,

/s/ Jonathan New

Jonathan New

Chief Financial Officer

Net Element, Inc.