SEC Comment Letter for STRATASYS LTD. (SSYS) (CIK 0001517396) (SSYS) — Feb 5, 2016
STRATASYS LTD. (SSYS) (CIK 0001517396)
Date: Feb. 5, 2016 · CIK: 0001517396 · Accession: 0000000000-16-063899
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35751
Letter
Mail Stop 4561 February 3, 2016 David Reis Chief Executive Officer Stratasys Ltd. 7665 Commerce Way Eden Prairie, MN 55344
Re: Stratasys Ltd. Form 20-F for Fiscal Year Ended December 31, 2014 Filed March 3 , 2015 Response dated January 13, 2016 File No. 001-35751
Dear Mr. Reis:
We have reviewed your letter dated January 13, 201 6 in connection with the above - referenced filing and have the following comment. Please respond to th is comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe o ur comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
General
1. In your response to prior comment 1 , you state that it is likely that a majority of your ordinary shares are held by U.S. residents , but argue that you do not meet any of the three conditions in the second part of the foreign private issuer definition in Rule 405 of the Securities Act. Please provide support for your respons e that a majority of your board and executive officers are not U.S. citizens or residents. Also provide support for your statement that significantly less than 50% of your assets were located in the United States. Explain in your response how you determi ned the location of your assets. Provide this information for each of the reporting periods presented in the Form 20 -F for the fiscal year ended December 31, 2014. Similar information should be provided for the most recently completed fiscal year.
David Reis Stratasys Ltd. February 3, 2016 Page 2
Please contact Gabriel Eckstein, Staff Attorney, at (202) 551 -3286 or me at (202) 551 - 3462 with any questions . If you require further assistance, you may contact Barbara C. Jacobs, Assistant Director, at (202) 551 -3730.
Sincerely,
/s/ Mark P. Shuman
Show Raw Text
Mail Stop 4561 February 3, 2016 David Reis Chief Executive Officer Stratasys Ltd. 7665 Commerce Way Eden Prairie, MN 55344 Re: Stratasys Ltd. Form 20-F for Fiscal Year Ended December 31, 2014 Filed March 3 , 2015 Response dated January 13, 2016 File No. 001-35751 Dear Mr. Reis: We have reviewed your letter dated January 13, 201 6 in connection with the above - referenced filing and have the following comment. Please respond to th is comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe o ur comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. General 1. In your response to prior comment 1 , you state that it is likely that a majority of your ordinary shares are held by U.S. residents , but argue that you do not meet any of the three conditions in the second part of the foreign private issuer definition in Rule 405 of the Securities Act. Please provide support for your respons e that a majority of your board and executive officers are not U.S. citizens or residents. Also provide support for your statement that significantly less than 50% of your assets were located in the United States. Explain in your response how you determi ned the location of your assets. Provide this information for each of the reporting periods presented in the Form 20 -F for the fiscal year ended December 31, 2014. Similar information should be provided for the most recently completed fiscal year. David Reis Stratasys Ltd. February 3, 2016 Page 2 Please contact Gabriel Eckstein, Staff Attorney, at (202) 551 -3286 or me at (202) 551 - 3462 with any questions . If you require further assistance, you may contact Barbara C. Jacobs, Assistant Director, at (202) 551 -3730. Sincerely, /s/ Mark P. Shuman Mark P. Shuman Branch Chief—Legal Office of Information Technologies and Services