SEC Company Response from XTI Aerospace, Inc. (XTIA) (CIK 0001529113) (XTIA) — Apr 4, 2014
XTI Aerospace, Inc. (XTIA) (CIK 0001529113)
Date: April 4, 2014 · CIK: 0001529113 · Accession: 0001398432-14-000134
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-191648
Letter
Via Edgar Correspondence Division of Corporation Finance Securities and Exchange Commission Sysorex Global Holdings Corp. Amendment No. 5 to Registration Statement on Form S-1 Filed March 21, 2014 File No. 333-191648
Dear Sir or Madam:
This letter is in response to the verbal comments received from the Staff, concerning the Registration Statement of Sysorex Global Holdings Corp. (the “Company”), on Form S-1 (File No. 333-191648), including all amendments thereto (the “Registration Statement”) filed with the Securities and Exchange Commission. We have filed an amendment to the Registration Statement (the “Amendment No. 6”) concurrently with this letter incorporating and/or responding to the requested changes. The comment issued by the Staff’s is summarized below.
Executive Compensation, page 71
1.
The Staff notes that the disclosure in the compensation table with respect to the executive officers only includes disclosure with respect to the CEO and CFO and requests that the Company include such disclosure as is necessary to satisfy Item 402(m)(2)(ii) of Regulation S-K. The Staff requested that the Company refer to Instruction 2 of Item 402(m)(2)(ii) of Regulation S-K.
Response:
The Company has amended the Registration Statement in response to the Staff’s comment. Please see pages 71-72 of the Amendment No. 6.
If you have any questions please do not hesitate to contact the undersigned at (650) 245-0053 or by email at ali@sysorex.com, Elliot H. Lutzker of Davidoff Hutcher & Citron LLP at (646) 428-3210 or by email at ehl@dhclegal.com or Kevin Friedmann of Richardson & Patel, LLP at (212) 566-5159 or by email at kfriedmann@richardsonpatel.com.
Sincerely,
SYSOREX GLOBAL HOLDINGS CORP.
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CORRESP 1 filename1.htm CORRESP April 4, 2014 Via Edgar Correspondence Barbara C. Jacobs Assistant Director Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Sysorex Global Holdings Corp. Amendment No. 5 to Registration Statement on Form S-1 Filed March 21, 2014 File No. 333-191648 Dear Sir or Madam: This letter is in response to the verbal comments received from the Staff, concerning the Registration Statement of Sysorex Global Holdings Corp. (the “Company”), on Form S-1 (File No. 333-191648), including all amendments thereto (the “Registration Statement”) filed with the Securities and Exchange Commission. We have filed an amendment to the Registration Statement (the “Amendment No. 6”) concurrently with this letter incorporating and/or responding to the requested changes. The comment issued by the Staff’s is summarized below. Executive Compensation, page 71 1. The Staff notes that the disclosure in the compensation table with respect to the executive officers only includes disclosure with respect to the CEO and CFO and requests that the Company include such disclosure as is necessary to satisfy Item 402(m)(2)(ii) of Regulation S-K. The Staff requested that the Company refer to Instruction 2 of Item 402(m)(2)(ii) of Regulation S-K. Response: The Company has amended the Registration Statement in response to the Staff’s comment. Please see pages 71-72 of the Amendment No. 6. If you have any questions please do not hesitate to contact the undersigned at (650) 245-0053 or by email at ali@sysorex.com, Elliot H. Lutzker of Davidoff Hutcher & Citron LLP at (646) 428-3210 or by email at ehl@dhclegal.com or Kevin Friedmann of Richardson & Patel, LLP at (212) 566-5159 or by email at kfriedmann@richardsonpatel.com. Sincerely, SYSOREX GLOBAL HOLDINGS CORP. By: /s/ Nadir Ali Nadir Ali Chief Executive Officer