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SEC Comment Letter for ChronoScale Holdings Corp (CHRN) (CIK 0001549084) (CHRN) — Apr 8, 2014

ChronoScale Holdings Corp (CHRN) (CIK 0001549084)
Date: April 8, 2014 · CIK: 0001549084 · Accession: 0000000000-14-017561

AI Filing Summary & Sentiment

File numbers found in text: 333-181229

Date
March 31, 2014
Author
/s/ Jay Ingram
Form
UPLOAD
Company
ChronoScale Holdings Corp (CHRN) (CIK 0001549084)

Letter

April 8, 201 4 Via E -mail Nathan Harding Chief Executive Officer Ekso Bionics Holdings , Inc. 1414 Harbour Way South, Suite 1201 Richmond, California 94804

Re: Ekso Bionics Holdings , Inc. Amendment No. 2 to Form 8-K Filed March 31, 2014 File No. 333-181229

Dear Mr. Harding :

We have reviewed your amended filing an d have the following comments.

General

1. We are in receipt of your request for confidential treatment in connection with Exhibit s 10.25, 10.26 and 10.27. Comments, if any, will be issued in a separate letter.

Consolidated Balance Sheets, page F -3

2. Tell us and disclose the nature of the security issuance costs that you have recorded on the balance sheet. We note at December 31, 2013 this balance represents approximately 14% of total assets and increased $938,000 from December 31, 2012 to December 31, 2013. Tell us and disclose your basis for capitalization and method of amortization as well as how you ass ess the asset for recoverability.

You may contact Jenn Do , Staff Accountant, at (202) 551 -3743 or Melissa Rocha , Senior Assistant Chief Accountant , at (202) 551 -3854 if you have questions regarding comments on the financial statements and re lated matters. Please contact Kamyar Daneshvar, Staff Attor ney, at (202) 551 -3787 or me at (202) 551 -3397 with any other questions.

Sincerely,
/s/ Jay Ingram

Show Raw Text
April 8, 201 4

Via E -mail
Nathan Harding
Chief Executive  Officer
Ekso Bionics Holdings , Inc.
1414 Harbour Way South, Suite 1201
Richmond, California 94804

Re: Ekso Bionics Holdings , Inc.
 Amendment No. 2 to Form 8-K
Filed March 31, 2014
File No. 333-181229

Dear Mr. Harding :

We have reviewed your amended filing an d have the following comments.

General

1. We are in receipt of your request for confidential treatment in connection with Exhibit s
10.25, 10.26 and 10.27.  Comments, if any, will be issued in a separate letter.

Consolidated Balance Sheets, page F -3

2. Tell us and disclose the nature of the security issuance costs that you have recorded on
the balance sheet.  We note at December 31, 2013 this balance represents approximately
14% of total assets and increased $938,000 from December 31, 2012 to December 31,
2013.  Tell us and disclose your basis for capitalization and method of amortization as
well as how you ass ess the asset for recoverability.

You may contact Jenn Do , Staff Accountant, at (202) 551 -3743 or Melissa Rocha , Senior
Assistant Chief Accountant , at (202) 551 -3854  if you have questions regarding comments on the
financial statements and re lated matters.   Please contact Kamyar Daneshvar, Staff Attor ney, at
(202) 551 -3787  or me at (202) 551 -3397 with any other questions.

Sincerely,

 /s/ Jay Ingram

Jay Ingram
Legal Branch Chief
cc: Michelle L. Basil  (via e -mail)