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SEC Company Response from INTELLIGENT BIO SOLUTIONS INC. (INBS) (CIK 0001725430) (INBS) — Aug 2, 2019

INTELLIGENT BIO SOLUTIONS INC. (INBS) (CIK 0001725430)
Date: Aug. 2, 2019 · CIK: 0001725430 · Accession: 0001493152-19-011561

AI Filing Summary & Sentiment

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Document Type
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SEC Posture
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Summary

Reasoning

File numbers found in text: 333-232557

Referenced dates: July 11, 2019

Date
Aug. 2, 2019
Author
/s/
Form
CORRESP
Company
INTELLIGENT BIO SOLUTIONS INC. (INBS) (CIK 0001725430)

Letter

Graubard Miller

The Chrysler Building

Lexington Avenue

New York, N.Y. 10174-1101

(212) 818-8800

facsimile

direct dial number

(212) 818-8881

(212) 818-8602

email address

eschwartz@graubard.com

August 2, 2019

Division of Corporation Finance

Office of Electronics and Machinery

Securities and Exchange Commission

F Street, N.E.

Washington, D.C. 20549

Re: Glucose Biosensor Systems (Greater China) Holdings, Inc.

Registration Statement on Form S-1

Filed July 5, 2019

File No. 333-232557

Ladies and Gentlemen:

On behalf of Glucose Biosensor Systems (Greater China) Holdings, Inc. (the “Company”), we respond as follows to the Staff’s comment letter, dated July 11, 2019, relating to the above-captioned Registration Statement on Form S-1 (“Registration Statement”). Captions and page references herein correspond to those set forth in the amended filing of the Registration Statement, a copy of which has been marked with the changes from the prior filing of the Registration Statement.

Please note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the response to each comment immediately thereafter.

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.

The Company has revised the disclosure as requested on pages 70 and 71 of the Registration Statement.

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.

The Company has revised the disclosure as requested on page 87 of the Registration Statement, to clarify that there currently is no public market for its common stock.

*************

If you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

Sincerely,
/s/
Eric T. Schwartz

Show Raw Text
CORRESP
1
filename1.htm

    Graubard
                                         Miller

        The
        Chrysler Building

        405
        Lexington Avenue

        New
        York, N.Y. 10174-1101

        (212)
        818-8800

    facsimile

    direct
    dial number

    (212)
    818-8881

    (212)
    818-8602

    email
    address

    eschwartz@graubard.com

August
2, 2019

Division
of Corporation Finance

Office
of Electronics and Machinery

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Glucose
    Biosensor Systems (Greater China) Holdings, Inc.

    Registration
    Statement on Form S-1

    Filed
    July 5, 2019

    File
    No. 333-232557

Ladies
and Gentlemen:

On
behalf of Glucose Biosensor Systems (Greater China) Holdings, Inc. (the “Company”), we respond as follows to
the Staff’s comment letter, dated July 11, 2019, relating to the above-captioned Registration Statement on Form S-1 (“Registration
Statement”). Captions and page references herein correspond to those set forth in the amended filing of the Registration
Statement, a copy of which has been marked with the changes from the prior filing of the Registration Statement.

Please
note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the response to each
comment immediately thereafter.

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.

The
Company has revised the disclosure as requested on pages 70 and 71 of the Registration Statement.

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.

The
Company has revised the disclosure as requested on page 87 of the Registration Statement, to clarify that there currently
is no public market for its common stock.

*************

If
you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

    Sincerely,

    /s/
    Eric T. Schwartz

    Eric
    T. Schwartz

    cc:
    Mr.
    Harry Simeonidis

    Spencer
    G. Feldman, Esq.