SEC Comment Letter for AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978) (AQB) — Nov 4, 2014
AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978)
Date: Nov. 4, 2014 · CIK: 0001603978 · Accession: 0000000000-14-054709
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36426
Referenced dates: October 6, 2014
Letter
November 3, 2014 Via E -mail Ronald L. Stotish Chief Executive Officer AquaBounty Technologies, Inc. Two Clock Tower Place, Suite 395 Maynard, MA 01754
Re: AquaBounty Technologies , Inc. Amendment No. 4 to Form 10-12B Filed October 24, 2014 File No. 001-36426
Dear Mr. Stotish :
We have reviewed your responses to the comments in our letter dated October 6, 2014 and have the following additional comments.
Item 1. Business, page 3
Regulatory Environment, page 8
Other Regulatory Approvals, page 11
1. You disclose that you currently have all regulatory approvals necessary to operate your demonstration farm in Panama, and you are in compliance in all material respects with all permits necessary to operate that facility. Please reconcile this disclos ure here with media accounts that you recently were fined for repeated violations of Panamanian regulations related to your required permits. Please discuss these violations in detail, including the remediation measures that were taken and the pote ntial impact they may have on your business, if any. Please also provide us , if available , with an English language translation of the Panama regulatory order.
Ronald L. Stotish AquaBounty Technologies, Inc. November 3, 2014 Page 2
You may con tact Patrick Kuhn at (202) 551 -3308 or Doug Jones at (202) 551 -3309 if you have questions regarding comments on the financial statements and related matters. Please contact Ryan Adams at (202) 551 -3191 or me at (202) 551 -3217 with any other questions.
Sincerely,
/s/ J. Nolan McWilliams
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November 3, 2014 Via E -mail Ronald L. Stotish Chief Executive Officer AquaBounty Technologies, Inc. Two Clock Tower Place, Suite 395 Maynard, MA 01754 Re: AquaBounty Technologies , Inc. Amendment No. 4 to Form 10-12B Filed October 24, 2014 File No. 001-36426 Dear Mr. Stotish : We have reviewed your responses to the comments in our letter dated October 6, 2014 and have the following additional comments. Item 1. Business, page 3 Regulatory Environment, page 8 Other Regulatory Approvals, page 11 1. You disclose that you currently have all regulatory approvals necessary to operate your demonstration farm in Panama, and you are in compliance in all material respects with all permits necessary to operate that facility. Please reconcile this disclos ure here with media accounts that you recently were fined for repeated violations of Panamanian regulations related to your required permits. Please discuss these violations in detail, including the remediation measures that were taken and the pote ntial impact they may have on your business, if any. Please also provide us , if available , with an English language translation of the Panama regulatory order. Ronald L. Stotish AquaBounty Technologies, Inc. November 3, 2014 Page 2 You may con tact Patrick Kuhn at (202) 551 -3308 or Doug Jones at (202) 551 -3309 if you have questions regarding comments on the financial statements and related matters. Please contact Ryan Adams at (202) 551 -3191 or me at (202) 551 -3217 with any other questions. Sincerely, /s/ J. Nolan McWilliams J. Nolan McWilliams Attorney -Advisor cc: Via-Email Bradley C. Brasser, Esq. Jones Day