SEC Comment Letter 0000000000-25-001328 to Phunware, Inc. (PHUN)
Phunware, Inc.
Date: Feb. 6, 2025 · CIK: 0001665300 · Accession: 0000000000-25-001328
AI Filing Summary & Sentiment
File numbers found in text: 001-37862
Letter
February 6, 2025 Troy Reisner Chief Financial Officer Phunware, Inc. 1002 West Avenue Austin, Texas 78701 Re:Phunware, Inc. Form 10-K and 10-K/A for the Fiscal Year Ended December 31, 2023 File No. 001-37862 Dear Troy Reisner: We note your November 1, 2024 response to prior comment 1 and your revised risk factor related to PhunCoin and PhunToken. Although we have completed our review of your filing and have no further comments, please note that our decision not to issue additional comments should not be interpreted to suggest that we agree with your analysis or conclusions as to whether PhunCoins or PhunTokens are securities under the federal securities laws. In addition, 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.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Jeffrey McPhaul
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February 6, 2025
Troy Reisner
Chief Financial Officer
Phunware, Inc.
1002 West Avenue
Austin, Texas 78701
Re:Phunware, Inc.
Form 10-K and 10-K/A for the Fiscal Year Ended December 31, 2023
File No. 001-37862
Dear Troy Reisner:
We note your November 1, 2024 response to prior comment 1 and your revised risk
factor related to PhunCoin and PhunToken. Although we have completed our review of your
filing and have no further comments, please note that our decision not to issue additional
comments should not be interpreted to suggest that we agree with your analysis or
conclusions as to whether PhunCoins or PhunTokens are securities under the federal
securities laws. In addition, 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.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Jeffrey McPhaul