SEC Comment Letter for Datavault AI Inc. (DVLT) (CIK 0001682149) (DVLT) — Jun 27, 2018
Datavault AI Inc. (DVLT) (CIK 0001682149)
Date: June 27, 2018 · CIK: 0001682149 · Accession: 0000000000-18-019778
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 23, 2018
Letter
Mail Stop 3030 June 2 7, 2018 Via E -mail Brett Moyer Chief Executive Officer Summit Semiconductor, Inc. 6840 Via Del Oro Ste. 280 San Jose, CA 95119
Re: Summit Semiconductor, Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed June 22, 2018 File No. 333 -224267
Dear Mr. Moyer :
We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.
Prospectus Summary, page 2
1. We note your revised disclosure on page 17 indicating you are in default under disclosed indebtedness. Please apply comment 3 in our letter dated May 23, 2018 to y our current registration statement. Specifically, given your disclosed default, please revise your prospectus summary to highlight, if true, that creditors can claim proceeds of this offering in absence of a waiver. Also, ensure your revised summary disc losure clarifies if any of these creditors are related persons as defined in Regulation S -K Item 404.
Brett Moyer Summit Semiconductor, Inc. June 2 7, 2018 Page 2
Please contact Caleb French at (202) 551 -6947 or me at (202) 551 -3528 with any questions.
Sincerely,
/s/ A manda Ravitz
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Mail Stop 3030 June 2 7, 2018 Via E -mail Brett Moyer Chief Executive Officer Summit Semiconductor, Inc. 6840 Via Del Oro Ste. 280 San Jose, CA 95119 Re: Summit Semiconductor, Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed June 22, 2018 File No. 333 -224267 Dear Mr. Moyer : We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Prospectus Summary, page 2 1. We note your revised disclosure on page 17 indicating you are in default under disclosed indebtedness. Please apply comment 3 in our letter dated May 23, 2018 to y our current registration statement. Specifically, given your disclosed default, please revise your prospectus summary to highlight, if true, that creditors can claim proceeds of this offering in absence of a waiver. Also, ensure your revised summary disc losure clarifies if any of these creditors are related persons as defined in Regulation S -K Item 404. Brett Moyer Summit Semiconductor, Inc. June 2 7, 2018 Page 2 Please contact Caleb French at (202) 551 -6947 or me at (202) 551 -3528 with any questions. Sincerely, /s/ A manda Ravitz Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: David E. Danovitch, Esq. Robinson Brog Leinwand Greene Genovese & Gluck, P.C.