SEC Comment Letter for ChronoScale Holdings Corp (CHRN) (CIK 0001549084) (CHRN) — Nov 21, 2016
ChronoScale Holdings Corp (CHRN) (CIK 0001549084)
Date: Nov. 21, 2016 · CIK: 0001549084 · Accession: 0000000000-16-101774
AI Filing Summary & Sentiment
Letter
Mail Stop 4631 November 18, 2016 Via E -mail Mr. Maximilian Scheder -Bieschin Chief Financial Officer Ekso Bionics Holdings, Inc. 1414 Harbour Way South, Suite 1201 Richmond, California 94804
Re: Ekso Bionics Holdings, Inc. Form 10-K for the Fiscal Year Ended Dec. 31, 2015 Filed March 14, 2016 Form 10 -Q for the Quarter Ended March 31, 2016 Filed May 10, 2016 Definitive Proxy on Schedule 14A Filed April 25, 2016 File No. 000 -55442
Dear Mr. Maximilian Scheder -Bieschin :
We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these co mments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response.
After reviewin g your response to these comments, we may have additional comments.
Form 10 -Q for the Quarter Ended 3/31/2016
Notes to Condensed Consolidated Financial Statements (unaudited), page 19
1. We note from your first quarter results made available o n your investor relations website that you have sold 25 demonstration Ekso Aerial devices related to the industrial division. This appears to be a transaction unrelated to existing segments. Please tell us how this transaction affected your 2016 first quar ter results.
Mr. Maximilian Scheder -Bieschin Ekso Bionics Holdings, Inc. November 18, 2016 Page 2
10-K for year ended December 31, 2015
Intellectual Property Out -Licensing, page 9
2. Please describe, and include in future filings, the nature of the licensing revenue you receive from Lockheed Martin Corporation and OttoBock Healthcare Product GmbH.
Definitive Proxy on Schedule 14A
Equity Awards, page 18
3. In future filings, please elaborate on the 2014 Equity Incentive Plan and how the Compensation Committee grants awards. In addition, please tell us why you omitted the tabular disclosure required by Item 402(d) of Regulation S -K for the option awards granted in 2015.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact me at (202) 551 -3355 if you have questions regarding comments on the financial statements and relat ed matters. Please contact Kathryn McHale at (202) 551 -3464 or Jay Ingram at (202) 551 -3397 with any other questions.
Sincerely,
/s/ Terence O ’Brien
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Mail Stop 4631 November 18, 2016 Via E -mail Mr. Maximilian Scheder -Bieschin Chief Financial Officer Ekso Bionics Holdings, Inc. 1414 Harbour Way South, Suite 1201 Richmond, California 94804 Re: Ekso Bionics Holdings, Inc. Form 10-K for the Fiscal Year Ended Dec. 31, 2015 Filed March 14, 2016 Form 10 -Q for the Quarter Ended March 31, 2016 Filed May 10, 2016 Definitive Proxy on Schedule 14A Filed April 25, 2016 File No. 000 -55442 Dear Mr. Maximilian Scheder -Bieschin : We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these co mments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response. After reviewin g your response to these comments, we may have additional comments. Form 10 -Q for the Quarter Ended 3/31/2016 Notes to Condensed Consolidated Financial Statements (unaudited), page 19 1. We note from your first quarter results made available o n your investor relations website that you have sold 25 demonstration Ekso Aerial devices related to the industrial division. This appears to be a transaction unrelated to existing segments. Please tell us how this transaction affected your 2016 first quar ter results. Mr. Maximilian Scheder -Bieschin Ekso Bionics Holdings, Inc. November 18, 2016 Page 2 10-K for year ended December 31, 2015 Intellectual Property Out -Licensing, page 9 2. Please describe, and include in future filings, the nature of the licensing revenue you receive from Lockheed Martin Corporation and OttoBock Healthcare Product GmbH. Definitive Proxy on Schedule 14A Equity Awards, page 18 3. In future filings, please elaborate on the 2014 Equity Incentive Plan and how the Compensation Committee grants awards. In addition, please tell us why you omitted the tabular disclosure required by Item 402(d) of Regulation S -K for the option awards granted in 2015. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact me at (202) 551 -3355 if you have questions regarding comments on the financial statements and relat ed matters. Please contact Kathryn McHale at (202) 551 -3464 or Jay Ingram at (202) 551 -3397 with any other questions. Sincerely, /s/ Terence O ’Brien Terence O’Brien Accounting Branch Chief Office of Manufacturing and Construction