SEC Company Response from INTELLIGENT BIO SOLUTIONS INC. (INBS) (CIK 0001725430) (INBS) — Sep 18, 2019
INTELLIGENT BIO SOLUTIONS INC. (INBS) (CIK 0001725430)
Date: Sept. 18, 2019 · CIK: 0001725430 · Accession: 0001493152-19-014291
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-232557
Referenced dates: August 16, 2019, August 29, 2019
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
September 18, 2019
Division of Corporation Finance
Office of Electronics and Machinery
Securities and Exchange Commission
F Street, N.E.
Washington, D.C. 20549
Re: GBS Inc. (formerly Glucose Biosensor Systems (Greater China) Holdings, Inc.)
Amendment No. 2 to Registration Statement on Form S-1
Filed August 21, 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 August 29, 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.
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.
Amendment No. 2 to Registration Statement on Form S-1 filed August 21, 2019
Exclusive Form Selection, page 84
1. We note your disclosure that “[o]ur stockholders investors will not be deemed to have waived compliance with the federal securities laws and the rules and regulations thereunder.” We note your similar disclosure in the last risk factor on page 32. As requested by our prior comment 2 in our letter dated August 16, 2019, please revise your prospectus to disclose that investors cannot waive compliance with the federal securities laws and the rules and regulations promulgated thereunder. Please also expand your related risk factor on page 32 to address the increased costs for investors to bring a claim to which your exclusive forum provision applies in the Court of Chancery or the federal district court for the District of Delaware.
The Company has revised the disclosure on pages 32 and 85 of the Registration Statement as requested.
*************
Securities and Exchange Commission
September 18, 2019
Page
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
September
18, 2019
Division
of Corporation Finance
Office
of Electronics and Machinery
Securities
and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
Re:
GBS
Inc. (formerly Glucose Biosensor Systems (Greater China) Holdings, Inc.)
Amendment
No. 2 to Registration Statement on Form S-1
Filed
August 21, 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 August 29, 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.
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.
Amendment
No. 2 to Registration Statement on Form S-1 filed August 21, 2019
Exclusive
Form Selection, page 84
1. We
note your disclosure that “[o]ur stockholders investors will not be deemed to have
waived compliance with the federal securities laws and the rules and regulations thereunder.”
We note your similar disclosure in the last risk factor on page 32. As requested by our
prior comment 2 in our letter dated August 16, 2019, please revise your prospectus to
disclose that investors cannot waive compliance with the federal securities laws and
the rules and regulations promulgated thereunder. Please also expand your related risk
factor on page 32 to address the increased costs for investors to bring a claim to which
your exclusive forum provision applies in the Court of Chancery or the federal district
court for the District of Delaware.
The
Company has revised the disclosure on pages 32 and 85 of the Registration Statement as requested.
*************
Securities
and Exchange Commission
September
18, 2019
Page
2
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.