SEC Comment Letter for Aditxt, Inc. (ADTX) (CIK 0001726711) (ADTX) — Jul 13, 2018
Aditxt, Inc. (ADTX) (CIK 0001726711)
Date: July 13, 2018 · CIK: 0001726711 · Accession: 0000000000-18-021566
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 024-10825
Letter
July 13, 2018 Amro Albanna Chief Executive OfficerADiTx Therapeutics, Inc.11161 Anderson St., Suite 105-10014Loma Linda, CA 92354 Re: ADiTx Therapeutics, Inc. Amendment No. 2 to Offering Statement on Form 1-AFiled on July 3, 2018File No. 024-10825 Dear Mr. Albanna: 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 wemay 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 andcircumstances or do not believe an amendment is appropriate, please tell us why in yourresponse. 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 noteotherwise, our references to prior comments are to comments in our June 11, 2018 letter. Amendment No. 2 to Offering Statement on Form 1-A Capitalization, page 39 1. In the third paragraph in this section, we note the disclosure that prior to this offering you entered into private placement transactions. Please include the dates of those transactions,including the date of issuance of the Private Placement Warrants. Exhibits 2. We note your response to our prior comment 6 and reissue in part. Please have counsel revise Exhibit 12.1 to state that the units will constitute a binding obligation of theDIVISION OF CORPORATION FINANCE UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON , D.C. 20549
FirstName LastNameAmro Albanna Comapany NameADiTx Therapeutics, Inc. July 13, 2018 Page 2 FirstName LastNameAmro Albanna ADiTx Therapeutics, Inc.July 13, 2018Page 2 company. Refer to Section II.B.1.h of Staff Legal Bulletin No. 19, available on our website www.sec.gov . You may contact Abe Friedman at (202) 551-8298 or Jean Yu at (202) 551-3305 if you have questions regarding comments on the financial statements and related matters. Pleasecontact Tonya K. Aldave at (202) 551-3601 or Susan Block at (202) 551-3210 with any otherquestions. Division of Corporation Finance Office of Transportation and Leisure cc: Richard Friedman, Esq.
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July 13, 2018
Amro Albanna
Chief Executive OfficerADiTx Therapeutics, Inc.11161 Anderson St., Suite 105-10014Loma Linda, CA 92354
Re: ADiTx Therapeutics, Inc.
Amendment No. 2 to Offering Statement on Form 1-AFiled on July 3, 2018File No. 024-10825
Dear Mr. Albanna:
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 wemay 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 andcircumstances or do not believe an amendment is appropriate, please tell us why in yourresponse.
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 noteotherwise, our references to prior comments are to comments in our June 11, 2018 letter.
Amendment No. 2 to Offering Statement on Form 1-A
Capitalization, page 39
1. In the third paragraph in this section, we note the disclosure that prior to this offering you
entered into private placement transactions. Please include the dates of those transactions,including the date of issuance of the Private Placement Warrants.
Exhibits
2. We note your response to our prior comment 6 and reissue in part. Please have counsel
revise Exhibit 12.1 to state that the units will constitute a binding obligation of theDIVISION OF
CORPORATION FINANCE UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON , D.C. 20549
FirstName LastNameAmro Albanna
Comapany NameADiTx Therapeutics, Inc. July 13, 2018 Page 2
FirstName LastNameAmro Albanna
ADiTx Therapeutics, Inc.July 13, 2018Page 2
company. Refer to Section II.B.1.h of Staff Legal Bulletin No. 19, available on our
website www.sec.gov .
You may contact Abe Friedman at (202) 551-8298 or Jean Yu at (202) 551-3305 if you
have questions regarding comments on the financial statements and related matters. Pleasecontact Tonya K. Aldave at (202) 551-3601 or Susan Block at (202) 551-3210 with any otherquestions.
Division of Corporation Finance
Office of Transportation and Leisure
cc: Richard Friedman, Esq.