SEC Company Response from Verax Research Services, Inc. (CIK 0001763987) — Mar 5, 2020
Verax Research Services, Inc. (CIK 0001763987)
Date: March 5, 2020 · CIK: 0001763987 · Accession: 0001477932-20-001084
AI Filing Summary & Sentiment
File numbers found in text: 024-11029
Letter
verax_corresp.htm
100 Pine Street, Suite 1250
San Francisco, California 94111
Tel: +1-(702) 275-2181 ⨝ Fax: +1-(619) 566-4028
john@dolkartlaw.com
Via Electronic Mail
March 5, 2020
Division of Corporation Finance
Attn: Staff Counsel Ronald Alper, Esq. and Brigette Lippman, Esq.
Office of Beverages, Apparel and Mining
U.S. Securities and Exchange Commission
Washington, D. C. 20549
alperr@sec.gov and lippmannb@sec.gov
Re:
Verax Research Services, Inc.
Amendment No. 3 to Its
Offering Statement on Form 1-A
Originally Filed June 28, 2019 File No. 024-11029
To Staff Counsel Mr. Alper and Ms. Lippman:
On or about June 28, 2019, in connection with the sale at $6.25 per share of up to 8,000,000 shares of common stock of Verax Research Services, Inc. (the “Company”), we filed the Company’s Form 1-A with the Securities and Exchange Commission (“SEC”) pursuant to Regulation A under the Securities Act of 1933, as amended. In response to the staff’s oral comments Friday, February 28, we herewith file this Amendment No. 3 (the “Amendment”) response to the staff’s comments.
Please note that this SEC Cover Letter (being filed concurrently as a “Communication” on EDGAR) relates to Amendment No. 3 to the Form 1-A (the “Amendment”) which is also being filed concurrently on EDGAR. As relayed in Amendment No. 1, the Company has named Dalmore Group, LLC as Selling Agent/accommodating broker. Such Broker-Dealer Agreement is filed as Exhibit 3.5 to this Amendment. In addition, Dalmore has filed its compensation arrangements with FINRA seeking FINRA’s advice that it has no objections to the compensation arrangements. We will advise the staff as soon as that notification is received, expected shortly after this Amendment is filed.
Finally, as requested, the Technology Licensing Agreement relating to the Cannacopeia Database has been filed as Exhibit 6.8 to this Amendment. We acknowledge 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.
Thank you for your on-going assistance and prompt review of these materials. Should you have any questions during the course of your review, please let me know.
Kind Regards,
/s/ John E. Dolkart, Jr., Esq.
John E. Dolkart, Jr., Esq.
Show Raw Text
CORRESP 1 filename1.htm verax_corresp.htm 100 Pine Street, Suite 1250 San Francisco, California 94111 Tel: +1-(702) 275-2181 ⨝ Fax: +1-(619) 566-4028 john@dolkartlaw.com Via Electronic Mail March 5, 2020 Division of Corporation Finance Attn: Staff Counsel Ronald Alper, Esq. and Brigette Lippman, Esq. Office of Beverages, Apparel and Mining U.S. Securities and Exchange Commission Washington, D. C. 20549 alperr@sec.gov and lippmannb@sec.gov Re: Verax Research Services, Inc. Amendment No. 3 to Its Offering Statement on Form 1-A Originally Filed June 28, 2019 File No. 024-11029 To Staff Counsel Mr. Alper and Ms. Lippman: On or about June 28, 2019, in connection with the sale at $6.25 per share of up to 8,000,000 shares of common stock of Verax Research Services, Inc. (the “Company”), we filed the Company’s Form 1-A with the Securities and Exchange Commission (“SEC”) pursuant to Regulation A under the Securities Act of 1933, as amended. In response to the staff’s oral comments Friday, February 28, we herewith file this Amendment No. 3 (the “Amendment”) response to the staff’s comments. Please note that this SEC Cover Letter (being filed concurrently as a “Communication” on EDGAR) relates to Amendment No. 3 to the Form 1-A (the “Amendment”) which is also being filed concurrently on EDGAR. As relayed in Amendment No. 1, the Company has named Dalmore Group, LLC as Selling Agent/accommodating broker. Such Broker-Dealer Agreement is filed as Exhibit 3.5 to this Amendment. In addition, Dalmore has filed its compensation arrangements with FINRA seeking FINRA’s advice that it has no objections to the compensation arrangements. We will advise the staff as soon as that notification is received, expected shortly after this Amendment is filed. Finally, as requested, the Technology Licensing Agreement relating to the Cannacopeia Database has been filed as Exhibit 6.8 to this Amendment. We acknowledge 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. Thank you for your on-going assistance and prompt review of these materials. Should you have any questions during the course of your review, please let me know. Kind Regards, /s/ John E. Dolkart, Jr., Esq. John E. Dolkart, Jr., Esq.