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SEC Company Response from Aeva Technologies, Inc. (AEVA, AEVA-WT) (CIK 0001789029) (AEVA) — Jan 8, 2020

Aeva Technologies, Inc. (AEVA, AEVA-WT) (CIK 0001789029)
Date: Jan. 8, 2020 · CIK: 0001789029 · Accession: 0001213900-20-000503

AI Filing Summary & Sentiment

Date
Jan. 8, 2020
Author
/s/ Jeffrey M. Gallant
Form
CORRESP
Company
Aeva Technologies, Inc. (AEVA, AEVA-WT) (CIK 0001789029)

Letter

Graubard Miller

The Chrysler Building

405 Lexington Avenue

New York, N.Y. 10174-1101

(212) 818-8800

facsimile

direct dial number

(212) 818-8881

(212) 818-8638

email address

jgallant@graubard.com

January 8, 2020

Securities and Exchange Commission

Division of Corporation Finance

Office of Financial Services

F Street, N.E.

Washington, D.C. 20549

Re: InterPrivate Acquisition Corp.

Draft Registration Statement on Form S-1

Submitted October 10, 2019

CIK No. 0001789029

Ladies and Gentlemen:

On behalf of InterPrivate Acquisition Corp. (the “Company”), we respond as follows to the Staff’s comment letter, dated November 6, 2019, relating to the above-captioned Draft Registration Statement on Form S-1 (“Registration Statement”). Captions and page references herein correspond to those set forth in amended filing of the Registration Statement, a copy of which has been marked with the changes from the prior draft submission of the Registration Statement.

Please note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the Company’s response to each comment immediately thereafter.

Draft Registration Statement on Form S-1

General

1. Please supplementally provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications.

We will supplementally provide the Staff with copies of any written communications that the Company, or anyone authorized to do so on the Company’s behalf, present to potential investors in reliance on Section 5(d) of the Securities Act of 1933, as amended, whether or not they retain copies of the communications, as requested.

Securities and Exchange Commission

Page

Proposed Business, page 45

2. We note you disclose the relationship with the InterPrivate platform as one of your competitive strengths. Please explain clearly what you mean by the InterPrivate platform.

We have revised the disclosure on page 45 of the Registration Statement as requested.

3. Please provide expanded disclosure of the relationship between InterPrivate and the family offices you reference, including the nature of the family offices and the extent of such relationship.

We have revised the disclosure on page 47 of the Registration Statement as requested.

Management, page 62

4. Please ensure that the information in this section regarding management's background is balanced, with equally prominent discussion of any management experience with similar transactions or business initiatives that generated losses for investors or that were not completed.

We have revised the disclosure on pages 1 and 46 of the Registration Statement as requested.

*************

If you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

Sincerely,
/s/ Jeffrey M. Gallant

Show Raw Text
CORRESP
1
filename1.htm

    Graubard
                                         Miller

                                         The Chrysler
                                         Building

                                         405 Lexington Avenue

                                         New York, N.Y. 10174-1101

                                         (212) 818-8800

    facsimile

    direct
    dial number

    (212)
    818-8881

    (212)
    818-8638

    email
    address

    jgallant@graubard.com

January
8, 2020

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Financial Services

100
F Street, N.E.

Washington,
D.C. 20549

 Re: InterPrivate
Acquisition Corp.

Draft
Registration Statement on Form S-1

Submitted
October 10, 2019

CIK
No. 0001789029

Ladies
and Gentlemen:

On
behalf of InterPrivate Acquisition Corp. (the “Company”), we respond as follows to the Staff’s comment letter,
dated November 6, 2019, relating to the above-captioned Draft Registration Statement on Form S-1 (“Registration Statement”).
Captions and page references herein correspond to those set forth in amended filing of the Registration Statement, a copy of which
has been marked with the changes from the prior draft submission of the Registration Statement.

Please
note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the Company’s
response to each comment immediately thereafter.

Draft
Registration Statement on Form S-1

General

 1. Please
                                         supplementally provide us with copies of all written communications, as defined in Rule
                                         405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
                                         present to potential investors in reliance on Section 5(d) of the Securities Act, whether
                                         or not they retain copies of the communications.

We
will supplementally provide the Staff with copies of any written communications that the Company, or anyone authorized to do so
on the Company’s behalf, present to potential investors in reliance on Section 5(d) of the Securities Act of 1933, as amended,
whether or not they retain copies of the communications, as requested.

Securities
and Exchange Commission

Page
2

Proposed
Business, page 45

 2. We
                                         note you disclose the relationship with the InterPrivate platform as one of your competitive
                                         strengths. Please explain clearly what you mean by the InterPrivate platform.

We
have revised the disclosure on page 45 of the Registration Statement as requested.

 3. Please
                                         provide expanded disclosure of the relationship between InterPrivate and the family offices
                                         you reference, including the nature of the family offices and the extent of such relationship.

We
have revised the disclosure on page 47 of the Registration Statement as requested.

Management,
page 62

 4. Please
                                         ensure that the information in this section regarding management's background is balanced,
                                         with equally prominent discussion of any management experience with similar transactions
                                         or business initiatives that generated losses for investors or that were not completed.

We
have revised the disclosure on pages 1 and 46 of the Registration Statement as requested.

*************

If
you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

    Sincerely,

    /s/ Jeffrey M. Gallant

    Jeffrey M. Gallant

 cc: Mr.
                                         Ahmed M. Fattouh