SEC Comment Letter for Catheter Precision, Inc. (VTAK) (CIK 0001716621) (VJET) — Sep 24, 2019
Catheter Precision, Inc. (VTAK) (CIK 0001716621)
Date: Sept. 24, 2019 · CIK: 0001716621 · Accession: 0000000000-19-013879
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File numbers found in text: 001-38677
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September 24, 2019
Andrew Jackson
Chief Financial Officer
Ra Medical Systems, Inc.
2070 Las Palmas Drive
Carlsbad, CA 92011
Re:Ra Medical Systems, Inc.
Form 10-K For the Fiscal Year Ended December 31, 2018
Filed March 15, 2019
Form 8-K filed August 12, 2019
File No. 001-38677
Dear Mr. Jackson:
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 business days by providing the requested
information or advise us as soon as possible when you will respond. 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 8-K filed August 12, 2019
Item 7.01 Regulation FD Disclosure
Independent Investigation
1.We see that the Audit Committee of the Board of Directors has commenced an
independent investigation into an anonymous complaint. Please clearly describe to us the
allegations made in the anonymous complaint, the circumstances which lead to the
investigation and the issues being investigated by the Audit Committee. Based on your
current understanding of the allegations and the investigation to date, tell us the areas of
your accounting or disclosure that could be impacted (e.g., revenues, impairments,
contingencies, etc.). In addition, describe to us your considerations to date of your
obligations under Item 4.02 of Form 8-K.
2.Please tell us when you intend to file your Form 10-Q for the quarterly period ended June
30, 2019.
FirstName LastNameAndrew Jackson
Comapany NameRa Medical Systems, Inc.
September 24, 2019 Page 2
FirstName LastName
Andrew Jackson
Ra Medical Systems, Inc.
September 24, 2019
Page 2
Exhibit 99.1
Manufacturing Update
3.We note you disclose here that you experienced inconsistencies in the DABRA catheter
manufacturing process and that it had an adverse impact on revenue during the fourth
quarter of 2018 and the first half of 2019. We also note discussions in your Form 10-K
and Form 10-Q of production limitations within MD&A. Please address the following:
•Bridge the gap between these two disclosures and clarify the specific manufacturing
issues encountered and, to the extent possible, the specific impact on your financial
statements for the referenced periods.
•Describe how you account for the catheters within your financial statement and clearly
articulate your accounting policies for catheter impairment and/or warranty claims.
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 Eric Atallah at (202) 551-3663 or Kevin Kuhar, Accounting Branch
Chief, at (202) 551-3662 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery