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SEC Company Response from BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961) (BINI) — Nov 16, 2017

BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)
Date: Nov. 16, 2017 · CIK: 0001499961 · Accession: 0001144204-17-059714

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File numbers found in text: 333-221148

Date
November 16, 2017
Author
/s/ Jonathan New
Form
CORRESP
Company
BOLLINGER INNOVATIONS, INC. (BINI) (CIK 0001499961)

Letter

VIA EDGAR Attention: Office of Information Technologies and Services Jeff Kauten, Attorney-Advisor Re: Net Element, Inc. Registration Statement on Form S-1 Filed November 15, 2017 File No. 333-221148

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, November 17, 2017, 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

Show Raw Text
CORRESP
1
filename1.htm

November 16, 2017

VIA EDGAR

U.S. Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

    Attention:

        Jan Woo, Legal Branch Chief

        Office of Information Technologies and Services

    Jeff Kauten, Attorney-Advisor

 Re: Net Element, Inc.

Registration Statement on Form S-1 Filed
November 15, 2017

File No. 333-221148

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, November 17, 2017, 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.