SEC Comment Letter for PULSE BIOSCIENCES, INC. (PLSE) (CIK 0001625101) (PLSE) — Sep 5, 2019
PULSE BIOSCIENCES, INC. (PLSE) (CIK 0001625101)
Date: Sept. 5, 2019 · CIK: 0001625101 · Accession: 0000000000-19-013215
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37744
Letter
September 5, 2019 Brian Dow Chief Financial Officer Pulse Biosciences, Inc. 3957 Point Eden Way Hayward, CA 94545 Re:Pulse Biosciences, Inc. Form 10-K for the Year Ended December 31, 2018 Filed March 14, 2019 Form 10-Q for the Quarterly Period Ended June 30, 2019 Filed August 8, 2019 File No. 001-37744 Dear Mr. Dow: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comments, 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-Q for the Quarterly Period Ended June 30, 2019 Item 6. Exhibits Exhibits 31.1 and 31.2, page 55 1.We note that the certifications provided do not include the language relating your internal control over financial reporting in paragraph 4 and do not include paragraph 4(b) in its entirety, although you are now beyond the transition period that allows this omission. 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 Form 10-Q for the period ended March 31, 2019.
FirstName LastNameBrian Dow Comapany NamePulse Biosciences, Inc. September 5, 2019 Page 2 FirstName LastName Brian Dow Pulse Biosciences, Inc. September 5, 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 Tara Harkins at (202)-551-3639 or Martin James, Senior Assistant Chief Accountant, at (202)-551-3671 with any questions. Sincerely, Division of Corporation Finance Office of Electronics and Machinery
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September 5, 2019
Brian Dow
Chief Financial Officer
Pulse Biosciences, Inc.
3957 Point Eden Way
Hayward, CA 94545
Re:Pulse Biosciences, Inc.
Form 10-K for the Year Ended December 31, 2018
Filed March 14, 2019
Form 10-Q for the Quarterly Period Ended June 30, 2019
Filed August 8, 2019
File No. 001-37744
Dear Mr. Dow:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comments, 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-Q for the Quarterly Period Ended June 30, 2019
Item 6. Exhibits
Exhibits 31.1 and 31.2, page 55
1.We note that the certifications provided do not include the language relating your internal
control over financial reporting in paragraph 4 and do not include paragraph 4(b) in its
entirety, although you are now beyond the transition period that allows this omission.
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 Form 10-Q for the period ended March 31, 2019.
FirstName LastNameBrian Dow
Comapany NamePulse Biosciences, Inc.
September 5, 2019 Page 2
FirstName LastName
Brian Dow
Pulse Biosciences, Inc.
September 5, 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 Tara Harkins at (202)-551-3639 or Martin James, Senior Assistant
Chief Accountant, at (202)-551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery