SEC Comment Letter 0000000000-22-013674 to Neuraxis, INC (NRXS) (CIK 0001933567) (NRXS)
Neuraxis, INC (NRXS) (CIK 0001933567)
Date: Dec. 19, 2022 · CIK: 0001933567 · Accession: 0000000000-22-013674
AI Filing Summary & Sentiment
Referenced dates: October 24, 2022
Letter
United States securities and exchange commission logo December 19, 2022 Brian Carrico Chief Executive Officer Neuraxis, Inc. 11550 N. Meridian Street, Suite 325 Carmel, IN 46032 Re:Neuraxis, Inc. Amendment No.2 to Draft Registration Statement on Form S-1 Submitted December 12, 2022 CIK No. 0001933567 Dear Brian Carrico: We have reviewed your amended draft registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 2 to Draft Registration Statement Submitted December 12, 2022 Prospectus Summary Pipeline, page 1 1.We note your pipeline table on pages 1 and 54. Please further revise the table as follows: •Expand the column entitled "Human Clinical Trials" to reflect the phases of clinical trials that must be completed prior to your 510k/De Novo FDA Submissions and ensure the arrow in each row is accurate regarding the company's progress. Please also revise your Government Regulation disclosure starting on page 63 to discuss the distinct phases. In the event there is not more than one phase required, please advise. •Please remove references to projected timelines in the narrative leading into the table and in the header to the table, as no actual timelines are reflected in the table itself.
FirstName LastNameBrian Carrico Comapany NameNeuraxis, Inc. December 19, 2022 Page 2 FirstName LastName Brian Carrico Neuraxis, Inc. December 19, 2022 Page 2 Refer to bullet three of comment 5 of our comment letter dated October 24, 2022. You may contact Gary Newberry at 202-551-3761 or Lynn Dicker at 202-551-3616 if you have questions regarding comments on the financial statements and related matters. Please contact Cindy Polynice at 202-551-8707 or Laura Crotty at 202-551-7614 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Tom Twedt
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United States securities and exchange commission logo
December 19, 2022
Brian Carrico
Chief Executive Officer
Neuraxis, Inc.
11550 N. Meridian Street, Suite 325
Carmel, IN 46032
Re:Neuraxis, Inc.
Amendment No.2 to Draft Registration Statement on Form S-1
Submitted December 12, 2022
CIK No. 0001933567
Dear Brian Carrico:
We have reviewed your amended draft registration statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement Submitted December 12, 2022
Prospectus Summary
Pipeline, page 1
1.We note your pipeline table on pages 1 and 54. Please further revise the table as follows:
•Expand the column entitled "Human Clinical Trials" to reflect the phases of clinical
trials that must be completed prior to your 510k/De Novo FDA Submissions and
ensure the arrow in each row is accurate regarding the company's progress. Please
also revise your Government Regulation disclosure starting on page 63 to discuss the
distinct phases. In the event there is not more than one phase required, please advise.
•Please remove references to projected timelines in the narrative leading into the table
and in the header to the table, as no actual timelines are reflected in the table itself.
FirstName LastNameBrian Carrico
Comapany NameNeuraxis, Inc.
December 19, 2022 Page 2
FirstName LastName
Brian Carrico
Neuraxis, Inc.
December 19, 2022
Page 2
Refer to bullet three of comment 5 of our comment letter dated October 24, 2022.
You may contact Gary Newberry at 202-551-3761 or Lynn Dicker at 202-551-3616 if
you have questions regarding comments on the financial statements and related matters. Please
contact Cindy Polynice at 202-551-8707 or Laura Crotty at 202-551-7614 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Tom Twedt