SEC Comment Letter for Vislink Technologies, Inc. (VISL) (CIK 0001565228) (VISL) — Sep 7, 2022
Vislink Technologies, Inc. (VISL) (CIK 0001565228)
Date: Sept. 7, 2022 · CIK: 0001565228 · Accession: 0000000000-22-009737
AI Filing Summary & Sentiment
File numbers found in text: 001-35988
Letter
United States securities and exchange commission logo September 7, 2022 Michael Bond Chief Financial Officer Vislink Technologies, Inc. 350 Clark Drive , Suite 125 Mt. Olive , NJ 07828 Re:Vislink Technologies, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 File No. 001-35988 Dear Mr. Bond: We have limited our review of your filing to the financial statements and related disclosures and 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 comments within ten business days by providing the requested information or advise 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 reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2021 Item 9A. Controls and Procedures, page 42 1.Please amend your filing to clearly and separately disclose your conclusions regarding the effectiveness of your disclosure controls and procedures and internal control over financial reporting as of December 31, 2021. See Items 307 and 308 of Regulation S-K. We note that your disclosure controls and procedures section references an assessment that "began in the second quarter of 2021 and is ongoing" and that the internal control over financial reporting section indicates that disclosure controls and procedures were not effective. Exhibits 31.1 and 31.2, page 47 2.Please revise the certifications provided in Exhibits 31.1 and 31.2 to include paragraph 4(b) and the introductory language in paragraph 4 referring to internal control over financial reporting. Refer to Item 601(b)(31) of Regulation S-K.
FirstName LastNameMichael Bond Comapany NameVislink Technologies, Inc. September 7, 2022 Page 2 FirstName LastName Michael Bond Vislink Technologies, Inc. September 7, 2022 Page 2 In closing, 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 Charles Eastman, Staff Accountant, at 202-551-3794 or Andrew Blume, Senior Staff Accountant at 202-551-3254 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
September 7, 2022
Michael Bond
Chief Financial Officer
Vislink Technologies, Inc.
350 Clark Drive , Suite 125
Mt. Olive , NJ 07828
Re:Vislink Technologies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
File No. 001-35988
Dear Mr. Bond:
We have limited our review of your filing to the financial statements and related
disclosures and 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 comments within ten business days by providing the requested
information or advise 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 reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 9A. Controls and Procedures, page 42
1.Please amend your filing to clearly and separately disclose your conclusions regarding the
effectiveness of your disclosure controls and procedures and internal control over
financial reporting as of December 31, 2021. See Items 307 and 308 of Regulation S-K.
We note that your disclosure controls and procedures section references an assessment
that "began in the second quarter of 2021 and is ongoing" and that the internal control
over financial reporting section indicates that disclosure controls and procedures were not
effective.
Exhibits 31.1 and 31.2, page 47
2.Please revise the certifications provided in Exhibits 31.1 and 31.2 to include
paragraph 4(b) and the introductory language in paragraph 4 referring to internal control
over financial reporting. Refer to Item 601(b)(31) of Regulation S-K.
FirstName LastNameMichael Bond
Comapany NameVislink Technologies, Inc.
September 7, 2022 Page 2
FirstName LastName
Michael Bond
Vislink Technologies, Inc.
September 7, 2022
Page 2
In closing, 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 Charles Eastman, Staff Accountant, at 202-551-3794 or Andrew Blume,
Senior Staff Accountant at 202-551-3254 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing