UPLOAD Filing
IR-Med, Inc.
Date: April 27, 2023 · CIK: 0001839133 · Accession: 0000000000-23-004286
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-56492
Letter
United States securities and exchange commission logo April 27, 2023 Sharon Levkoviz Chief Financial Officer IR-Med, Inc. ZHR Industrial Zone Rosh Pina, Israel Re:IR-Med, Inc. Form 10-K filed March 29, 2023 File No. 000-56492 Dear Sharon Levkoviz : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year ended December 31, 2022 Item 9A. Controls and Procedures, page 50 1.You indicate that as of December 31, 2022, your disclosure controls and procedures (DCP) were effective. Please explain how you reached this conclusion. In this regard, we note the Item 4 disclosures in your Form 10-Q for the quarter ended September 30, 2022, indicate that the two material material weaknesses identified in your assessment of internal controls over financial reporting (ICFR) as of December 31, 2021, were still not remediated. In light of this disclosure, as well as your current disclosure that during the quarter ended December 31, 2022, there were no changes in your ICFR that have materially affected, or are reasonably likely to materially affect, your ICFR, it is unclear how the two material weaknesses were sufficiently remediated in order for you to conclude that your DCP was effective as of December 31, 2022. Please revise your disclosures accordingly.
2.You do not provide a conclusion of the effectiveness of ICFR. With reference to our
FirstName LastNameSharon Levkoviz Comapany NameIR-Med, Inc. April 27, 2023 Page 2 FirstName LastName Sharon Levkoviz IR-Med, Inc. April 27, 2023 Page 2 above concerns regarding the material weaknesses previously identified, please revise your disclosures to conclude on the effectiveness of your ICFR. 3.Your conclusion regarding the effectiveness of DCP refers to COSO. Please revise this disclosure as COSO is used for an assessment of ICFR.
4.To the extent you have remediated your previously identified material weaknesses, please address the need to revise your disclosures under the caption, Changes in Internal Controls Over Financial Reporting. In closing, we remind you 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. You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551- 3355 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
Show Raw Text
United States securities and exchange commission logo
April 27, 2023
Sharon Levkoviz
Chief Financial Officer
IR-Med, Inc.
ZHR Industrial Zone
Rosh Pina, Israel
Re:IR-Med, Inc.
Form 10-K filed March 29, 2023
File No. 000-56492
Dear Sharon Levkoviz :
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year ended December 31, 2022
Item 9A. Controls and Procedures, page 50
1.You indicate that as of December 31, 2022, your disclosure controls and procedures
(DCP) were effective. Please explain how you reached this conclusion. In this regard, we
note the Item 4 disclosures in your Form 10-Q for the quarter ended September 30, 2022,
indicate that the two material material weaknesses identified in your assessment of
internal controls over financial reporting (ICFR) as of December 31, 2021, were still not
remediated. In light of this disclosure, as well as your current disclosure that during the
quarter ended December 31, 2022, there were no changes in your ICFR that have
materially affected, or are reasonably likely to materially affect, your ICFR, it is unclear
how the two material weaknesses were sufficiently remediated in order for you to
conclude that your DCP was effective as of December 31, 2022. Please revise your
disclosures accordingly.
2.You do not provide a conclusion of the effectiveness of ICFR. With reference to our
FirstName LastNameSharon Levkoviz
Comapany NameIR-Med, Inc.
April 27, 2023 Page 2
FirstName LastName
Sharon Levkoviz
IR-Med, Inc.
April 27, 2023
Page 2
above concerns regarding the material weaknesses previously identified, please revise
your disclosures to conclude on the effectiveness of your ICFR.
3.Your conclusion regarding the effectiveness of DCP refers to COSO. Please revise this
disclosure as COSO is used for an assessment of ICFR.
4.To the extent you have remediated your previously identified material weaknesses, please
address the need to revise your disclosures under the caption, Changes in Internal Controls
Over Financial Reporting.
In closing, we remind you 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.
You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-
3355 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services