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SEC Company Response from Pulmatrix, Inc. (PULM) (CIK 0001574235) (PULM) — Nov 18, 2013

Pulmatrix, Inc. (PULM) (CIK 0001574235)
Date: Nov. 18, 2013 · CIK: 0001574235 · Accession: 0001144204-13-062796

AI Filing Summary & Sentiment

File numbers found in text: 333-190476

Date
November 18, 2013
Author
Not clearly detected
Form
CORRESP
Company
Pulmatrix, Inc. (PULM) (CIK 0001574235)

Letter

Ruthigen, Inc.

2455 Bennett Valley Rd., Suite C116

Santa Rosa, California 95404

November 18, 2013

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jeffrey Riedler, Assistant Director

Re: Ruthigen, Inc.

Registration Statement on Form S-1

File No. 333-190476

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Ruthigen, Inc. (the “Registrant”) hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-190476), as amended (the “Registration Statement”), so that it may become effective at 4:00 p.m. (Washington, D.C. time) on November 20, 2013, or as soon thereafter as practicable. Under separate cover, you will receive a letter from the managing underwriter of the proposed offering joining in the Registrant’s request for acceleration of the effectiveness of the Registration Statement.

The Registrant hereby acknowledges that:

(i)

should the U.S. Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(ii)

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii)

the Registrant 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.

[remainder of page intentionally left blank]

Please call Linda K. Rockett (617-348-4888) of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Company, with any comments or questions regarding this matter.

Very truly yours,
Ruthigen, Inc.

Show Raw Text
CORRESP
1
filename1.htm

Ruthigen, Inc.

2455 Bennett Valley Rd., Suite C116

Santa Rosa, California 95404

November 18, 2013

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jeffrey Riedler, Assistant Director

 Re: Ruthigen, Inc.

Registration
Statement on Form S-1

File
No. 333-190476

Request
for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461
of Regulation C promulgated under the Securities Act of 1933, as amended, Ruthigen, Inc. (the “Registrant”) hereby
requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-190476), as amended (the
“Registration Statement”), so that it may become effective at 4:00 p.m. (Washington, D.C. time) on November 20, 2013,
or as soon thereafter as practicable. Under separate cover, you will receive a letter from the managing underwriter of the proposed
offering joining in the Registrant’s request for acceleration of the effectiveness of the Registration Statement.

The Registrant hereby acknowledges that:

    (i)

    should the U.S. Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

    (ii)

    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

    (iii)

    the Registrant 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.

[remainder of page intentionally left
blank]

 	Please
call Linda K. Rockett (617-348-4888) of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.,
counsel to the Company, with any comments or questions regarding this matter.

    Very truly yours,

Ruthigen, Inc.

    By:
    /s/ Hojabr Alimi

    Name:
    Hojabr Alimi

    Title:
    Chief Executive Officer, Chief Science Officer and

Chairman of the Board of Directors

 cc: Securities and Exchange Commission

Jeffrey Riedler, Assistant
Director

Ibolya Ignat

Mark Brunhofer

Amy Reischauer

Daniel Greenspan

    Ruthigen, Inc.

    Hojabr Alimi,
     Chief Executive Officer, Chief Science Officer and

     Chairman of the Board of Directors

    Sameer Harish, Chief Financial Officer

Mintz, Levin,
Cohn, Ferris, Glovsky and Popeo, P.C.

Ivan
K. Blumenthal, Esq.

Linda
K. Rockett, Esq.

Sichenzia Ross
Friedman Ference LLP

Jeffrey J. Fessler,
Esq.

Stephen A. Cohen, Esq.

Marcum LLP

Anthony Basile

Mitchell Watt