SEC Comment Letter for INTELLIGENT BIO SOLUTIONS INC. (INBS) (CIK 0001725430) (INBS) — Jul 11, 2019
INTELLIGENT BIO SOLUTIONS INC. (INBS) (CIK 0001725430)
Date: July 11, 2019 · CIK: 0001725430 · Accession: 0000000000-19-010995
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-232557
Letter
July 11, 2019 Harry Simeonidis President Glucose Biosensor Systems (Greater China) Holdings, Inc. 708 Third Avenue, 6th Floor New York, New York 10017 Re:Glucose Biosensor Systems (Greater China) Holdings, Inc. Registration Statement on Form S-1 Filed July 5, 2019 File No. 333-232557 Dear Mr. Simeonidis: We have reviewed your 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. Registration Statement on Form S-1 filed July 5, 2019 Executive Compensation, page 70 1.Please update the disclosure in this section to be as of your most recently completed fiscal year, June 30, 2019, including all required tables. Determination of Offering Price, page 86 2.We note your disclosure that there has been a "very limited public market" for your common stock. Revise to clarify where there has been a public market for your shares or revise as appropriate.
FirstName LastNameHarry Simeonidis Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc. July 11, 2019 Page 2 FirstName LastName Harry Simeonidis Glucose Biosensor Systems (Greater China) Holdings, Inc. July 11, 2019 Page 2 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Michael Fay at (202) 551-3812 or Gary Todd, Senior Accountant, at (202) 551-3605 if you have questions regarding comments on the financial statements and related matters. Please contact Tim Buchmiller at (202) 551-3635 or Geoff Kruczek, Special Counsel, at (202) 551-3641 with any other questions. Sincerely, Division of Corporation Finance Office of Electronics and Machinery cc: Eric T. Schwartz, Esq.
Show Raw Text
July 11, 2019
Harry Simeonidis
President
Glucose Biosensor Systems (Greater China) Holdings, Inc.
708 Third Avenue, 6th Floor
New York, New York 10017
Re:Glucose Biosensor Systems (Greater China) Holdings, Inc.
Registration Statement on Form S-1
Filed July 5, 2019
File No. 333-232557
Dear Mr. Simeonidis:
We have reviewed your 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.
Registration Statement on Form S-1 filed July 5, 2019
Executive Compensation, page 70
1.Please update the disclosure in this section to be as of your most recently completed fiscal
year, June 30, 2019, including all required tables.
Determination of Offering Price, page 86
2.We note your disclosure that there has been a "very limited public market" for your
common stock. Revise to clarify where there has been a public market for your shares or
revise as appropriate.
FirstName LastNameHarry Simeonidis
Comapany NameGlucose Biosensor Systems (Greater China) Holdings, Inc.
July 11, 2019 Page 2
FirstName LastName
Harry Simeonidis
Glucose Biosensor Systems (Greater China) Holdings, Inc.
July 11, 2019
Page 2
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
You may contact Michael Fay at (202) 551-3812 or Gary Todd, Senior Accountant, at
(202) 551-3605 if you have questions regarding comments on the financial statements and
related matters. Please contact Tim Buchmiller at (202) 551-3635 or Geoff Kruczek, Special
Counsel, at (202) 551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc: Eric T. Schwartz, Esq.