SEC Comment Letter 0000000000-25-004273 to MEDICAL EXERCISE INC. (CIK 0002001249)
MEDICAL EXERCISE INC. (CIK 0002001249)
Date: April 23, 2025 · CIK: 0002001249 · Accession: 0000000000-25-004273
AI Filing Summary & Sentiment
File numbers found in text: 333-284522
Letter
April 23, 2025 Matthew Degelman President and Director Medical Exercise Inc. 11951 US-1, Suite 105 North Palm Beach, FL 33408 Re:Medical Exercise Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed April 21, 2025 File No. 333-284522 Dear Matthew Degelman: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our April 11, 2025 letter. Amendment No. 2 to Form S-1 filed April 21, 2025 Medical Exercise Inc.'s Technology and Treatment, page 28 1.We note your revised disclosure in response to prior comment 4 and reissue the comment. You state here that Medical Exercise Inc.’s Lumbar and Cervical Extension Machines are "backed by extensive research" and are "proven to help clients strengthen their spinal muscles, even after other treatments have failed." Please expand your disclosure relating to this extensive research by discussing it directly in the prospectus rather than providing a link to information on MedX's website.
April 23, 2025 Page 2 Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact Conlon Danberg at 202-551-4466 or Jane Park at 202-551-7439 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc:Scott D. Olson, Esq.
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April 23, 2025
Matthew Degelman
President and Director
Medical Exercise Inc.
11951 US-1, Suite 105
North Palm Beach, FL 33408
Re:Medical Exercise Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed April 21, 2025
File No. 333-284522
Dear Matthew Degelman:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our April 11, 2025 letter.
Amendment No. 2 to Form S-1 filed April 21, 2025
Medical Exercise Inc.'s Technology and Treatment, page 28
1.We note your revised disclosure in response to prior comment 4 and reissue the
comment. You state here that Medical Exercise Inc.’s Lumbar and Cervical Extension
Machines are "backed by extensive research" and are "proven to help clients
strengthen their spinal muscles, even after other treatments have failed." Please
expand your disclosure relating to this extensive research by discussing it directly in
the prospectus rather than providing a link to information on MedX's website.
April 23, 2025
Page 2
Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters. Please
contact Conlon Danberg at 202-551-4466 or Jane Park at 202-551-7439 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Scott D. Olson, Esq.