SEC Company Response from Phunware, Inc. (PHUN) (CIK 0001665300) (PHUN) — Apr 27, 2018
Phunware, Inc. (PHUN) (CIK 0001665300)
Date: April 27, 2018 · CIK: 0001665300 · Accession: 0001213900-18-005065
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37862
Letter
VIA EDGAR Office of Electronics and Machinery 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. Kuhar:
Stellar Acquisition III Inc. (the “Company”, “we”, “us” or “our”) hereby transmits its response to the letter received by us from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated April 19, 2018 regarding our Form 10-K for the Fiscal Year Ended November 30, 2017 (the “10-K”) previously filed on February 12, 2018.
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 Item 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.
In response to the Staff’s comments, we have revised the certifications to include the introductory language in paragraph 4 referring to internal control over financial reporting and filed the corrected certifications as exhibits 31.1 and 31.2 to Amendment No.1 to the 10-K.
We thank the Staff for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel, Stuart Neuhauser at sneuhauser@egsllp.com or by telephone at (212) 370-1300.
Very truly yours,
/s/ George Syllantavos
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CORRESP
1
filename1.htm
Stellar
Acquisition III Inc.
90
Kifissias Avenue
Maroussi
Athens, Greece
April 27, 2018
VIA
EDGAR
U.S.
Securities and Exchange Commission
Office
of Electronics and Machinery
100
F Street, N.E.
Mail
Stop 3030
Washington,
DC 20549
Attn:
Kevin J. Kuhar, Accounting Branch Chief
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. Kuhar:
Stellar Acquisition III
Inc. (the “Company”, “we”, “us” or “our”) hereby transmits
its response to the letter received by us from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”), dated April 19, 2018 regarding our Form 10-K for the Fiscal Year Ended November 30, 2017
(the “10-K”) previously filed on February 12, 2018.
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 Item 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.
In response to the Staff’s comments, we have revised
the certifications to include the introductory language in paragraph 4 referring to internal control over financial reporting and
filed the corrected certifications as exhibits 31.1 and 31.2 to Amendment No.1 to the 10-K.
We thank the Staff for
its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel, Stuart
Neuhauser at sneuhauser@egsllp.com or by telephone at (212) 370-1300.
Very truly yours,
/s/ George Syllantavos
George Syllantavos, Co-Chief Executive Officer and Chief Financial Officer
cc:
Ellenoff Grossman & Schole LLP