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SEC Comment Letter for AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978) (AQB) — Apr 18, 2018

AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978)
Date: April 18, 2018 · CIK: 0001603978 · Accession: 0000000000-18-011876

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-224184

Date
April 18, 2018
Author
J. Nolan McWilliams
Form
UPLOAD
Company
AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978)

Letter

April 18, 2018 David Frank Chief Financial Officer AquaBounty Technologies, Inc. Two Mill & Main Place, Suite 395 Maynard, MA 01754 Re:AquaBounty Technologies, Inc. Registration Statement on Form S-3 Filed April 6, 2018 File No. 333-224184 Dear Mr. Frank: We have limited our review of your registration statement to those issues we have addressed in our 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form S-3 General 1.To the extent you intend to rely on General Instruction I.B.6 to Form S-3 for limited primary offerings, please disclose on the prospectus cover page the information called for by Instruction 7 to General Instruction I.B.6. Please also confirm to us your understanding of the size limitations for offerings made pursuant to General Instruction I.B.6. 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.

FirstName LastNameDavid Frank Comapany NameAquaBounty Technologies, Inc. June 16, 2017 Page 2 FirstName LastName David Frank AquaBounty Technologies, Inc. April 18, 2018 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact J. Nolan McWilliams, Attorney-Advisor, at (202) 551-3217 or Justin Dobbie, Legal Branch Chief, at (202) 551-3469 with any questions you may have. Division of Corporation Finance Office of Transportation and Leisure

Show Raw Text
April 18, 2018
David Frank
Chief Financial Officer
AquaBounty Technologies, Inc.
Two Mill & Main Place, Suite 395
Maynard, MA 01754
Re:AquaBounty Technologies, Inc.
Registration Statement on Form S-3
Filed April 6, 2018
File No. 333-224184
Dear Mr. Frank:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-3
General
1.To the extent you intend to rely on General Instruction I.B.6 to Form S-3 for limited
primary offerings, please disclose on the prospectus cover page the information called for
by Instruction 7 to General Instruction I.B.6.  Please also confirm to us your
understanding of the size limitations for offerings made pursuant to General Instruction
I.B.6.
            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.

 FirstName LastNameDavid Frank
 Comapany NameAquaBounty Technologies, Inc.
 June 16, 2017 Page 2
 FirstName LastName
David Frank
AquaBounty Technologies, Inc.
April 18, 2018
Page 2
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact J. Nolan McWilliams, Attorney-Advisor, at (202) 551-3217 or Justin
Dobbie, Legal Branch Chief, at (202) 551-3469 with any questions you may have.
Division of Corporation Finance
Office of Transportation and Leisure