SEC Comment Letter for Electromedical Technologies, Inc (EMED) (CIK 0001715819) (EMED) — Jan 23, 2018
Electromedical Technologies, Inc (EMED) (CIK 0001715819)
Date: Jan. 23, 2018 · CIK: 0001715819 · Accession: 0000000000-18-002346
AI Filing Summary & Sentiment
Letter
Mail Stop 3030 January 22, 2018 Via E -mail Matthew N. Wolfson Chief Executive Officer Electromedical Technologies, Inc. 16561 N 92nd Street, Suite 101 Scottsdale, AZ 85260
Re: Electromedical Technologies, Inc. Amendment No. 2 to Offering Statement on Form 1-A Filed January 12, 2018 File No. 024 -10743
Dear Mr. Wolfson :
We have reviewed your amended offering 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 offering 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 offering statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 29, 2017 letter .
Part II – Offering Circular
Offering Perks, page 19
1. We note your response to prior comment 2. Please revise your disclosure to clarify that you offer your Wellness Pro Plus devices retail at variable deep discounts to distributors.
Matthew N. Wolfson Electromedical Technologies, Inc. January 22, 2018 Page 2
Please contact Tom Jones at (202) 551 -3602 or me at (202) 551 -3528 with any questions.
Sincerely,
/s/ Amanda Ravitz
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Mail Stop 3030 January 22, 2018 Via E -mail Matthew N. Wolfson Chief Executive Officer Electromedical Technologies, Inc. 16561 N 92nd Street, Suite 101 Scottsdale, AZ 85260 Re: Electromedical Technologies, Inc. Amendment No. 2 to Offering Statement on Form 1-A Filed January 12, 2018 File No. 024 -10743 Dear Mr. Wolfson : We have reviewed your amended offering 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 offering 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 offering statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 29, 2017 letter . Part II – Offering Circular Offering Perks, page 19 1. We note your response to prior comment 2. Please revise your disclosure to clarify that you offer your Wellness Pro Plus devices retail at variable deep discounts to distributors. Matthew N. Wolfson Electromedical Technologies, Inc. January 22, 2018 Page 2 Please contact Tom Jones at (202) 551 -3602 or me at (202) 551 -3528 with any questions. Sincerely, /s/ Amanda Ravitz Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Jamie Ostrow, Esq.