SEC Comment Letter for PAVmed Inc. (PAVM) (CIK 0001624326) (PAVM) — Sep 26, 2019
PAVmed Inc. (PAVM) (CIK 0001624326)
Date: Sept. 26, 2019 · CIK: 0001624326 · Accession: 0000000000-19-013984
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File numbers found in text: 001-37685
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September 26, 2019
Dennis M. McGrath
Chief Financial Officer
PAVmed Inc.
One Grand Central Place, Suite 4600
New York, NY 10165
Re:PAVmed Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed April 1, 2019
File No. 001-37685
Dear Mr. McGrath:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2018
Exhibits, page 51
1.We note that the certifications filed as Exhibits 31.1 and 31.2 exclude the introductory
language regarding internal control over financial reporting in the fourth
paragraph. Please amend the filing to provide revised certifications that include the
required information. You may file an abbreviated amendment that is limited to the cover
page, explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certifications.
Refer to Exchange Act Rule 13a-14(a) and Item 601(b)(31) of Regulation S-K. This
comment also applies to your Forms 10-Q for the quarterly periods ended March 31, 2019
and June 30, 2019.
FirstName LastNameDennis M. McGrath
Comapany NamePAVmed Inc.
September 26, 2019 Page 2
FirstName LastName
Dennis M. McGrath
PAVmed Inc.
September 26, 2019
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 Eric Atallah at (202) 551-3663 or Tara Harkins, Senior Accountant, at
(202) 551-3639 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery