SEC Company Response from BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961) (BINI) — Jul 23, 2015
BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)
Date: July 23, 2015 · CIK: 0001499961 · Accession: 0001144204-15-043863
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File numbers found in text: 333-204840
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CORRESP
1
filename1.htm
July 23, 2015
VIA EDGAR
U.S. Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Re: Net Element, Inc.
Registration
Statement on Form S-3
Filed
July 21, 2015
File
No. 333-204840
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 Registration Statement, as amended, be accelerated so that the
Registration Statement may become effective on Friday, July 24, 2015, at 3:00 pm (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 Registration Statement.
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.