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SEC Company Response from electroCore, Inc. (ECOR) (CIK 0001560258) (ECOR) — Jun 19, 2018

electroCore, Inc. (ECOR) (CIK 0001560258)
Date: June 19, 2018 · CIK: 0001560258 · Accession: 0001193125-18-196747

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File numbers found in text: 333-225084

Date
June 19, 2018
Author
ELECTROCORE, LLC
Form
CORRESP
Company
electroCore, Inc. (ECOR) (CIK 0001560258)

Letter

Via EDGAR Office of Electronics and Machinery Division of Corporation Finance File No. 333-225084 Acceleration Request Requested Date: June 21, 2018 Requested Time: 4:00 PM Eastern Time

Dear Ms. Ravitz:

Electrocore, LLC (the “Company”), pursuant to Rule 461 under the Securities Act of 1933, as amended, hereby requests that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that the Registration Statement may become effective at the “Requested Date” and “Requested Time” set forth above or at such later time as the Company or its counsel, Dentons US LLP, may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”).

Once the Registration Statement has been declared effective, please orally confirm that event with Ira L. Kotel of Dentons US LLP, counsel to the Company, at (212) 398-5787.

The Company hereby acknowledges that:

•

should the Commission or the Staff, 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 Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert 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.

In addition, the Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement.

Sincerely,
ELECTROCORE, LLC

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 150 Allen Road, Suite 201

Basking Ridge, New Jersey 07920

 June 19, 2018

 Via
EDGAR

 Amanda Ravitz

 Assistant Director

Office of Electronics and Machinery

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F. Street,
N.E.

 Washington, D.C. 20549

 Re:  Electrocore, LLC

       Registration Statement on Form
S-1

        File No. 333-225084

 Acceleration Request

 Requested Date:
June 21, 2018

 Requested Time: 4:00 PM Eastern Time

 Dear Ms. Ravitz:

Electrocore, LLC (the “Company”), pursuant to Rule 461 under the Securities Act of 1933, as amended, hereby requests that the
effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that the Registration Statement may become effective at the “Requested Date” and “Requested Time”
set forth above or at such later time as the Company or its counsel, Dentons US LLP, may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission
(the “Commission”).

 Once the Registration Statement has been declared effective, please orally confirm that event with Ira L.
Kotel of Dentons US LLP, counsel to the Company, at (212) 398-5787.

 The Company hereby
acknowledges that:

•

should the Commission or the Staff, 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 Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

the Company may not assert 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.

 In addition, the Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as
amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement.

Sincerely,

ELECTROCORE, LLC

 By:

 /s/ Glenn S. Vraniak

 Name: Glenn S. Vraniak

 Title: Chief Financial Officer

cc:
Francis R. Amato, Electrocore, LLC

Joseph P. Errico, Electrocore, LLC

John L. Cleary, II, Esq., Dentons US LLP

Peter N. Handrinos, Esq., Latham & Watkins LLP

Nathan Ajiashvili, Esq., Latham & Watkins LLP

Brian Cascio, U.S. Securities and Exchange Commission

Tim Buchmiller, U.S. Securities and Exchange Commission

Geoff Kruczek, U.S. Securities and Exchange Commission

Kristin Lochhead, U.S. Securities and Exchange Commission