SEC Comment Letter for SenesTech, Inc. (SNES) (CIK 0001680378) (SNES) — Oct 31, 2017
SenesTech, Inc. (SNES) (CIK 0001680378)
Date: Oct. 31, 2017 · CIK: 0001680378 · Accession: 0000000000-17-038513
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37941
Letter
Mail Stop 3561 October 31, 2017 Thomas C. Chesterman Chief Financial Officer SenesTech, Inc. 3140 N. Caden Court Suite 1 Flagstaff, AZ 86004
Re: SenesTech, Inc. Form 10-K for the Fiscal Year Ended December 31, 2016 Filed March 31, 2017 File No. 001-37941
Dear Mr. Chesterman :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will re spond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2016
Risks Related to Our Business Operations and History, page 22
1. We note your disclosure in the second risk factor on page 23 that “We have not been required to and have not filed an annual report for fiscal 2016, so pursuant to SEC regulations, we are not yet required to evaluate the effectiveness of our internal control over financial reporting.” As this document is your annual report for fiscal 2016, please revise your disclosure to comply with Instruction 1 to Item 308 of Regulation S -K to include a st atement regarding the transition period established for newly public companies.
Thomas C. Chesterman SenesTech, Inc. October 31, 2017 Page 2
Note 2: Summary of Significant Accounting Policies, page F -12
2. Please expand your disclosure here and in your Form 10 -Q’s to provide the information in SAB Topic 11:M fo r FASB ASU 2014 -09, Revenue from Contracts with Customers (Topic 606).
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 Theresa Brillant at 202-551-3307 or me at 202-551-3380 if you have questions regarding comments on the financial statements and rel ated matters.
Sincerely,
/s/ Lyn Shenk
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Mail Stop 3561 October 31, 2017 Thomas C. Chesterman Chief Financial Officer SenesTech, Inc. 3140 N. Caden Court Suite 1 Flagstaff, AZ 86004 Re: SenesTech, Inc. Form 10-K for the Fiscal Year Ended December 31, 2016 Filed March 31, 2017 File No. 001-37941 Dear Mr. Chesterman : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will re spond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2016 Risks Related to Our Business Operations and History, page 22 1. We note your disclosure in the second risk factor on page 23 that “We have not been required to and have not filed an annual report for fiscal 2016, so pursuant to SEC regulations, we are not yet required to evaluate the effectiveness of our internal control over financial reporting.” As this document is your annual report for fiscal 2016, please revise your disclosure to comply with Instruction 1 to Item 308 of Regulation S -K to include a st atement regarding the transition period established for newly public companies. Thomas C. Chesterman SenesTech, Inc. October 31, 2017 Page 2 Note 2: Summary of Significant Accounting Policies, page F -12 2. Please expand your disclosure here and in your Form 10 -Q’s to provide the information in SAB Topic 11:M fo r FASB ASU 2014 -09, Revenue from Contracts with Customers (Topic 606). 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 Theresa Brillant at 202-551-3307 or me at 202-551-3380 if you have questions regarding comments on the financial statements and rel ated matters. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief Office of Transportation and Leisure