Correspondence 0001493152-25-006463 from IMAC Holdings, Inc. (BACK) (CIK 0001729944) (BACK)
IMAC Holdings, Inc. (BACK) (CIK 0001729944)
Date: Feb. 13, 2025 · CIK: 0001729944 · Accession: 0001493152-25-006463
AI Filing Summary & Sentiment
File numbers found in text: 333-280184
Letter
VIA EDGAR AND EMAIL Division of Corporation Finance, Office of Industrial Applications and Services Attention: Juan Grana Re: IMAC Holdings, Inc. (the “Company” or “IMAC”) Amendment No. 2 to Registration Statement on Form S-1 Filed February 12, 2025 File No. 333-280184
Dear Mr. Grana and Ms. Bagley:
In response to your oral comments delivered by telephone to the Company’s counsel on February 12, 2025 (the “Oral Comments”), please see below IMAC’s responses to your comments and revisions in connection there with included in Amendment No. 3 to the Registration Statement on Form S-1, File No. 333-280184 as filed with the Securities and Exchange Commission on February 13, 2025 (“S-1 Amendment No. 3”). We have included your comments in italics for reference.
Amendment No. 2 to Registration Statement on Form S-1
General
1. Resubmit Exhibits 10.35 and 10.36 in a format that is text-searchable.
RESPONSE: In response to Oral Comment No. 1, the Company has filed Exhibits 10.35 and 10.36 with the S-1 Amendment No. 3 in a format that is text-searchable.
Prospectus Summary, page 3
2. Provide more information about the clinical data referred to in the Strategy section to substantiate the disclosure about such clinical data.
RESPONSE: In response to Oral Comment No. 2, the Company has revised the disclosure in S-1 Amendment No. 3 to provide fulsome disclosure regarding the clinical data. The Company is hereby submitting marked pages set forth on Exhibit A hereto showing proposed changes to the S-1 Amendment No. 3.
Securities and Exchange Commission
February 13, 2025
Page 2
Prospectus Summary, page 4
3. Revise the disclosure on page 4 to state that the Company cannot guarantee it will meet the requirements of such new rules or obtain any requisite approvals required by new rules.
RESPONSE: In response to Comment No. 3, the Company has revised the disclosure in S-1 Amendment No. 3 to disclaim any implied guarantee that the Company will be able to meet the requirements of any applicable future rule. The Company is hereby submitting marked pages set forth on Exhibit B hereto showing proposed changes to the S-1 Amendment No. 3.
If you require any further information or have additional questions, please contact me at (818) 613-0151 or our counsel, Carol W. Sherman of Kelley Drye & Warren LLP, at (212) 808-5038.
Sincerely,
/s/ Faith Zaslavsky
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CORRESP
1
filename1.htm
February
13, 2025
VIA
EDGAR AND EMAIL
U.S.
Securities and Exchange Commission
Division
of Corporation Finance, Office of Industrial Applications and Services
100
F Street, NE
Washington,
D.C. 20549
Attention: Juan Grana
Katherine Bagley
Re: IMAC Holdings, Inc. (the “Company” or “IMAC”)
Amendment No. 2 to Registration Statement on Form S-1
Filed February 12, 2025
File No. 333-280184
Dear
Mr. Grana and Ms. Bagley:
In
response to your oral comments delivered by telephone to the Company’s counsel on February 12, 2025 (the “Oral Comments”),
please see below IMAC’s responses to your comments and revisions in connection there with included in Amendment No. 3 to the Registration
Statement on Form S-1, File No. 333-280184 as filed with the Securities and Exchange Commission on February 13, 2025 (“S-1 Amendment
No. 3”). We have included your comments in italics for reference.
Amendment
No. 2 to Registration Statement on Form S-1
General
1. Resubmit Exhibits 10.35 and 10.36 in a format that is text-searchable.
RESPONSE:
In response to Oral Comment No. 1, the Company has filed Exhibits 10.35 and 10.36 with the S-1 Amendment No. 3 in a format that is text-searchable.
Prospectus
Summary, page 3
2. Provide
more information about the clinical data referred to in the Strategy section to substantiate the disclosure about such clinical data.
RESPONSE:
In response to Oral Comment No. 2, the Company has revised the disclosure in S-1 Amendment No. 3 to provide fulsome disclosure regarding
the clinical data. The Company is hereby submitting marked pages set forth on Exhibit A hereto showing proposed changes to the S-1 Amendment
No. 3.
Securities and Exchange Commission
February 13, 2025
Page 2
Prospectus
Summary, page 4
3. Revise
the disclosure on page 4 to state that the Company cannot guarantee it will meet the requirements of such new rules or obtain any requisite
approvals required by new rules.
RESPONSE:
In response to Comment No. 3, the Company has revised the disclosure in S-1 Amendment No. 3 to disclaim any implied guarantee that the
Company will be able to meet the requirements of any applicable future rule. The Company is hereby submitting marked pages set forth
on Exhibit B hereto showing proposed changes to the S-1 Amendment No. 3.
If
you require any further information or have additional questions, please contact me at (818) 613-0151 or our counsel, Carol W. Sherman
of Kelley Drye & Warren LLP, at (212) 808-5038.
Sincerely,
/s/ Faith Zaslavsky
Faith Zaslavsky
Chief Executive Officer
cc: Carol
W. Sherman
EXHIBIT
A
A-1
A-2
A-3
Exhibit
B
B-1