SEC Comment Letter 0000000000-23-007014 to Aditxt, Inc. (ADTX)
Aditxt, Inc.
Date: June 30, 2023 · CIK: 0001726711 · Accession: 0000000000-23-007014
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File numbers found in text: 001-39336
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United States securities and exchange commission logo
June 30, 2023
Amro Albanna
Chief Executive Officer
Aditxt, Inc.
737 N. Fifth Street, Suite 200
Richmond, VA 232129
Re:Aditxt, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed April 17, 2023
File No. 001-39336
Dear Amro Albanna:
We have reviewed your filings and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9A. Controls and Procedures, page 48
1.Please amend your Form 10-K to provide management’s report
on internal control over financial reporting as of December 31, 2022 as required by Item
308(a) of Regulation S-K. Include the framework management used to evaluate the
effectiveness of internal control over financial reporting and a definitive conclusion as to
their effectiveness in accordance with Items 308(a)(2) and 308(a)(3) of Regulation S-K.
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.
FirstName LastNameAmro Albanna
Comapany NameAditxt, Inc.
June 30, 2023 Page 2
FirstName LastName
Amro Albanna
Aditxt, Inc.
June 30, 2023
Page 2
You may contact Tara Harkins at (202) 551-3639 or Lynn Dicker, Reviewing
Accountant, at (202) 551-3616 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences