SEC Comment Letter for Serina Therapeutics, Inc. (SER) (CIK 0001708599) (SER) — May 18, 2020
Serina Therapeutics, Inc. (SER) (CIK 0001708599)
Date: May 18, 2020 · CIK: 0001708599 · Accession: 0000000000-20-004406
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United States securities and exchange commission logo
May 18, 2020
Andrea Park
Chief Financial Officer
AgeX Therapeutics, Inc.
965 Atlantic Avenue, Suite 101
Alameda, California 94501
Re:AgeX Therapeutics, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 30, 2020
File No: 1-38519
Dear Ms. Park:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this comment within ten business days by providing the requested
information 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 December 31, 2019
Controls and Procedures, page 99
1.You state that a report of management’s assessment regarding internal control over
financial reporting is not included "due to a transition period established by rules of the
Securities and Exchange Commission for newly public companies." Please tell us your
consideration of Item 308(a) of Regulation S-K, particularly the Instructions thereto,
which indicate that such transition period would apply to only the first annual report.
Alternatively, amend your filing to so provide.
FirstName LastNameAndrea Park
Comapany NameAgeX Therapeutics, Inc.
May 18, 2020 Page 2
FirstName LastName
Andrea Park
AgeX Therapeutics, Inc.
May 18, 2020
Page 2
In closing, 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 Tracey McKoy, Staff Accountant, at (202)551-3772. In her absence
you may contact Jennifer Do, Staff Accountant, at (202)551-3743 or, Terence O'Brien,
Accounting Branch Chief, at (202)551-3355 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences