SEC Comment Letter for AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978) (AQB) — Dec 20, 2016
AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978)
Date: Dec. 20, 2016 · CIK: 0001603978 · Accession: 0000000000-16-105694
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 December 20, 2016 Ronald L. Stotish Chief Executive Officer AquaBounty Technologies, Inc. 2 Mill and Main Place, Suite 395 Maynard, MA 01754
Re: AquaBounty Technologies, Inc. Amendment No. 1 to Form 10 -12B Filed December 12 , 2016 File No. 001 -36426
Dear Mr. Stotish:
We have reviewed your amended registration statement 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 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 reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in ou r December 2, 2016 letter .
Exhibit 99.1
Atlantic Salmon Disease Impact, page 5 8
1. We note your response to comment 15. Please briefly discuss the reasons for your belief that the RAS that you use comprise a less disease -prone environment than the sea cag es employed in conventional salmon aquaculture.
Our Product, page 5 9
2. We note your response to prior comment 16. Please clarify that you relied on internally generated data to support your statement that AquaAdvantage salmon do not reach a
Ronald L. Stotish AquaBounty Technologies, Inc. December 20, 2016 Page 2
larger final size than their traditional counterparts. Additionally, please briefly explain to us how t he table that you present in your response support s this conclusion.
You may contact 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 Julie Griffith at 202 -551-3267 or me at 202-551-3217 with any other questions.
Sincerely,
/s/ J. Nolan McWilliams
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Mail Stop 3561
December 20, 2016
Ronald L. Stotish
Chief Executive Officer
AquaBounty Technologies, Inc.
2 Mill and Main Place, Suite 395
Maynard, MA 01754
Re: AquaBounty Technologies, Inc.
Amendment No. 1 to Form 10 -12B
Filed December 12 , 2016
File No. 001 -36426
Dear Mr. Stotish:
We have reviewed your amended registration statement 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 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 reviewing your response to these comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in ou r December 2,
2016 letter .
Exhibit 99.1
Atlantic Salmon Disease Impact, page 5 8
1. We note your response to comment 15. Please briefly discuss the reasons for your belief
that the RAS that you use comprise a less disease -prone environment than the sea cag es
employed in conventional salmon aquaculture.
Our Product, page 5 9
2. We note your response to prior comment 16. Please clarify that you relied on internally
generated data to support your statement that AquaAdvantage salmon do not reach a
Ronald L. Stotish
AquaBounty Technologies, Inc.
December 20, 2016
Page 2
larger final size than their traditional counterparts. Additionally, please briefly explain to
us how t he table that you present in your response support s this conclusion.
You may contact 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 Julie Griffith at 202 -551-3267 or me at 202-551-3217 with any other questions.
Sincerely,
/s/ J. Nolan McWilliams
J. Nolan McWilliams
Attorney -Advisor
Office of Transportation and Leisure