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: 0001398432-14-000137
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-191648
Letter
Sysorex Global Holdings Corp.
3375 Scott Blvd., Suite 440
Santa Clara, CA 95054
April 4, 2014
VIA EDGAR CORRESPONDENCE
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attn: Barbara C. Jacobs, Assistant Director
Re:
Sysorex Global Holdings Corp.
Registration Statement on Form S-1 (File No. 333-191648)
Acceleration Request
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended Sysorex Global Holdings Corp. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-referenced Registration Statement effective on Form S-l (File No. 333-191648) on April 8, 2014 at 4:00 P.M. Eastern Time, or as soon thereafter as practicable.
Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Davidoff Hutcher & Citron, LLP, by calling Elliot H. Lutzker at (646) 428-3288. The Company hereby authorizes Mr. Lutzker to orally modify or withdraw this request for acceleration.
In connection with this acceleration request, the Company hereby acknowledges that:
·
should the Commission or the staff of the Commission, 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
·
the Registrant may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely,
Sysorex Global Holdings Corp.
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CORRESP 1 filename1.htm CORRESP Sysorex Global Holdings Corp. 3375 Scott Blvd., Suite 440 Santa Clara, CA 95054 April 4, 2014 VIA EDGAR CORRESPONDENCE Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attn: Barbara C. Jacobs, Assistant Director Re: Sysorex Global Holdings Corp. Registration Statement on Form S-1 (File No. 333-191648) Acceleration Request Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended Sysorex Global Holdings Corp. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-referenced Registration Statement effective on Form S-l (File No. 333-191648) on April 8, 2014 at 4:00 P.M. Eastern Time, or as soon thereafter as practicable. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Davidoff Hutcher & Citron, LLP, by calling Elliot H. Lutzker at (646) 428-3288. The Company hereby authorizes Mr. Lutzker to orally modify or withdraw this request for acceleration. In connection with this acceleration request, the Company hereby acknowledges that: · should the Commission or the staff of the Commission, 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and · the Registrant may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Sincerely, Sysorex Global Holdings Corp. By: /s/ Nadir Ali Nadir Ali Chief Executive Officer cc: Elliot H. Lutzker, Davidoff Hutcher & Citron, LLP Kevin Friedmann, Richardson & Patel LLP Ernest M. Stern, Akerman LLP