SEC Comment Letter 0000000000-24-005843 to Aditxt, Inc. (ADTX)
Aditxt, Inc.
Date: May 20, 2024 · CIK: 0001726711 · Accession: 0000000000-24-005843
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-276588
Letter
United States securities and exchange commission logo May 20, 2024 Amro Albanna Chief Executive Officer Aditxt, Inc. 737 N. Fifth Street, Suite 200 Richmond, VA 23219 Re:Aditxt, Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed May 14, 2024 File No. 333-276588 Dear Amro Albanna: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe this comment applies 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 this letter, we may have additional comments. Unless we note otherwise, any reference to a prior comment is to the comment in our February 15, 2024 letter. Amendment No. 3 to Registration Statement on Form S-1 Notes to the Consolidated Financial Statements Note 3 - Summary of Significant Accounting Policies Investments, page F-12 1.We note your disclosure that you appear to have purchased equity investments in the amount of $22,711,211, which corresponds to an investment in Evofem on your balance sheet. Please provide us your analysis of accounting for this investment under the cost method and how you concluded that you do not exercise significant influence over Evofem such that financial statements pursuant to Rule 3-09 of Regulation S-X would be required. In addition, please confirm you continue to believe the acquisition of Evofem is not probable such that financial statements and pro forma information are not required under Rule 3-05 and Article 11 of Regulation S-X.
FirstName LastNameAmro Albanna Comapany NameAditxt, Inc. May 20, 2024 Page 2 FirstName LastName Amro Albanna Aditxt, Inc. May 20, 2024 Page 2 Please contact Tracie Mariner at 202-551-3744 or Mary Mast at 202-551-3613 if you have questions regarding comments on the financial statements and related matters. Please contact Jimmy McNamara at 202-551-7349 or Tim Buchmiller at 202-551-3635 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Sean F. Reid, Esq.
Show Raw Text
United States securities and exchange commission logo
May 20, 2024
Amro Albanna
Chief Executive Officer
Aditxt, Inc.
737 N. Fifth Street, Suite 200
Richmond, VA 23219
Re:Aditxt, Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed May 14, 2024
File No. 333-276588
Dear Amro Albanna:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe this comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any reference to a prior comment is to the comment in our February 15, 2024 letter.
Amendment No. 3 to Registration Statement on Form S-1
Notes to the Consolidated Financial Statements
Note 3 - Summary of Significant Accounting Policies
Investments, page F-12
1.We note your disclosure that you appear to have purchased equity investments in the
amount of $22,711,211, which corresponds to an investment in Evofem on your balance
sheet. Please provide us your analysis of accounting for this investment under the cost
method and how you concluded that you do not exercise significant influence over
Evofem such that financial statements pursuant to Rule 3-09 of Regulation S-X would be
required. In addition, please confirm you continue to believe the acquisition of Evofem is
not probable such that financial statements and pro forma information are not required
under Rule 3-05 and Article 11 of Regulation S-X.
FirstName LastNameAmro Albanna
Comapany NameAditxt, Inc.
May 20, 2024 Page 2
FirstName LastName
Amro Albanna
Aditxt, Inc.
May 20, 2024
Page 2
Please contact Tracie Mariner at 202-551-3744 or Mary Mast at 202-551-3613 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jimmy McNamara at 202-551-7349 or Tim Buchmiller at 202-551-3635 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Sean F. Reid, Esq.