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Correspondence 0001140361-24-040071 from Momentus Inc. (MNTS)

Momentus Inc.
Date: Sept. 4, 2024 · CIK: 0001781162 · Accession: 0001140361-24-040071

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File numbers found in text: 001-39128

Referenced dates: August 20, 2024

Date
September 4, 2024
Author
/s/ Paul Ney
Form
CORRESP
Company
Momentus Inc.

Letter

Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing Re: Momentus Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-39128

Dear Mr. Blume and Mr. Woody:

By your letter dated August 20, 2024 (the “SEC Letter”), the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) provided comments to the Annual Report on Form 10-K, as amended (the “10-K”), originally filed with the Staff on June 6, 2024, by Momentus Inc. (the “Company”). This letter sets forth the Company’s response with respect to the comments contained in the SEC Letter.

For your convenience, we have set forth below the Staff’s comments in bold typeface followed by the Company’s response thereto.

Form 10-K for the Fiscal Year Ended December 31, 2023

Item 9A. Controls and Procedures, page 98

1.

Please amend your filing to clearly and separately disclose your conclusions regarding the effectiveness of your disclosure controls and procedures and internal control over financial reporting as of December 31, 2023. See Items 307 and 308 of Regulation S-K.

Response:

The Company acknowledges the Staff’s comment and will file an amendment to the 10-K to revise Item 9.A to separately disclose its conclusions regarding the effectiveness of its disclosure controls and procedures and internal control over financial reporting as of December 31, 2023.

If you have any further requirements, please contact the undersigned at (669) 293-1444 or paul.ney@momentusspace.com.

Sincerely,
/s/ Paul Ney

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CORRESP
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    Momentus Inc.

     3901 N. First Street

    San Jose, California

    September 4, 2024

    Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

          Attn:

            Andrew Blume

    Kevin Woody

          Re:

            Momentus Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2023

    File No. 001-39128

    Dear Mr. Blume and Mr. Woody:

    By your letter dated August 20, 2024 (the “SEC Letter”), the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”)
      provided comments to the Annual Report on Form 10-K, as amended (the “10-K”), originally filed with the Staff on June 6, 2024, by Momentus Inc. (the “Company”). This letter sets forth the Company’s response with respect to the comments contained in
      the SEC Letter.

    For your convenience, we have set forth below the Staff’s comments in bold typeface followed by the Company’s response thereto.

    Form 10-K for the Fiscal Year Ended December 31, 2023

    Item 9A. Controls and Procedures, page 98

          1.

            Please amend your filing to clearly and separately disclose your conclusions regarding the effectiveness of your disclosure controls and procedures and internal
              control over financial reporting as of December 31, 2023. See Items 307 and 308 of Regulation S-K.

    Response:

    The Company acknowledges the Staff’s comment and will file an amendment to the 10-K to revise Item 9.A to separately disclose its conclusions regarding the effectiveness
      of its disclosure controls and procedures and internal control over financial reporting as of December 31, 2023.

    If you have any further requirements, please contact the undersigned at (669) 293-1444 or paul.ney@momentusspace.com.

            Sincerely,

            /s/ Paul Ney

            Paul Ney

            Chief Legal Officer and Corporate Secretary, Momentus Inc.

              cc:

              Stephen C. Hinton, Bradley Arant Boult Cummings LLP