SEC Comment Letter for Phunware, Inc. (PHUN) (CIK 0001665300) (PHUN) — Apr 19, 2018
Phunware, Inc. (PHUN) (CIK 0001665300)
Date: April 19, 2018 · CIK: 0001665300 · Accession: 0000000000-18-012047
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37862
Letter
Mail Stop 3030 April 19 , 2018 Via E -mail George Syllantavos Chief Financial Officer Stellar Acquisition III Inc. 90 Kifissias Avenue Maroussi Athens, Greece
Re: Stellar Acquisition III Inc. Form 10-K for the Fiscal Year Ended November 30, 2017 Filed February 12, 2018 File No. 001-37862
Dear Mr. Syllantavos :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 comment within ten business days by providing the requested informatio n 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 November 30, 2017
Exhibits 31.1 and 31.2
1. We note that your certifications do not include the introductory language in paragraph 4 referring to internal control over financial reporting. Please refer to Ite m 601(b)(31) of Regulation S -K and Section 246.13 of the Regulation S -K Compliance & Disclosure Interpretations and amend the filing to include corrected certifications.
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.
George Syllantavos Stellar Acquisition III Inc. April 1 9, 2018 Page 2
You may contact Eric Atallah at (202) 551 -3663 or me at (202) 551 -3662 with any questions. You may also reach Martin James, Senior Assistant Chief Accountant, at ( 202) 551 - 3671 .
Sincerely,
/s/ Kevin J. Kuhar
Show Raw Text
Mail Stop 3030
April 19 , 2018
Via E -mail
George Syllantavos
Chief Financial Officer
Stellar Acquisition III Inc.
90 Kifissias Avenue
Maroussi Athens, Greece
Re: Stellar Acquisition III Inc.
Form 10-K for the Fiscal Year Ended November 30, 2017
Filed February 12, 2018
File No. 001-37862
Dear Mr. Syllantavos :
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. 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 comment within ten business days by providing the requested
informatio n 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 November 30, 2017
Exhibits 31.1 and 31.2
1. We note that your certifications do not include the introductory language in paragraph 4
referring to internal control over financial reporting. Please refer to Ite m 601(b)(31) of
Regulation S -K and Section 246.13 of the Regulation S -K Compliance & Disclosure
Interpretations and amend the filing to include corrected certifications.
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.
George Syllantavos
Stellar Acquisition III Inc.
April 1 9, 2018
Page 2
You may contact Eric Atallah at (202) 551 -3663 or me at (202) 551 -3662 with any
questions. You may also reach Martin James, Senior Assistant Chief Accountant, at ( 202) 551 -
3671 .
Sincerely,
/s/ Kevin J. Kuhar
Kevin J. Kuhar
Accounting Branch Chief
Office of Electronics and Machinery