Correspondence 0001493152-24-043715 from DataMeds AI, Inc. (WGRX)
DataMeds AI, Inc.
Date: Nov. 5, 2024 · CIK: 0002030763 · Accession: 0001493152-24-043715
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-280945
Letter
Division of Corporate Finance Office of Trade & Services Attention: Rucha Pandit Re: Wellgistics Health, Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed October 21, 2024 File No. 333-280945
Dear Ms. Pandit:
This response letter (this “Response”) is submitted on behalf of Wellgistics Health, Inc. (the “Company”) in response to the comments that the Company received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) in a letter addressed to Mr. Canning, dated November 4, 2024 (the “Comment Letter”), with respect to the Company’s Amendment No. 3 to Registration Statement on Form S-1 (the “Registration Statement”), filed with the SEC on October 21, 2024. The Company is concurrently submitting a fourth amendment to the Registration Statement (“Amendment No. 4”), which reflects the changes discussed in this Response that the Company made to address the Staff’s comments.
For reference purposes, each of the Staff’s numbered comments from the Comment Letter is set forth in bold text below, followed by the Company’s response to each comment. All capitalized terms used but not defined in this Response have the meanings ascribed to them in Amendment No. 4. Unless noted otherwise, any references to prior comments are to comments in the Staff’s October 15, 2024 letter.
The responses below are based on information provided to Dykema Gossett PLLC by the Company.
Amendment No. 3 to Registration Statement on Form S-1
Capitalization, page 44
1. Please explain why there are differences in cash and accumulated deficit amounts in the Pro Forma column as compared to page 49.
Response: In response the Staff’s comment, the Company has revised the applicable disclosure on page 44 of Amendment No. 4 to correct the discrepancy.
California | Illinois | Michigan | Minnesota | Texas | Washington, D.C. | Wisconsin
U.S. Securities and Exchange Commission
Division of Corporate Finance
November 5, 2024
Page
Danam Health, Inc.
Statement of Operations, page F-4
2. Please provide us your calculation of net loss per common share.
Response: In response the Staff’s comment, the Company has revised the applicable disclosure on page F-4 of Amendment No. 4.
Community Specialty Pharmacy, LLC
Independent Auditors’ Report, page F-95
3. Please have your auditor specify the period(s) covered by each financial statement identified in the report and the period(s) to which the opinion applies. Refer to paragraph 8c of AS 3101.
Response: In response the Staff’s comment, the Company’s auditor has revised the applicable disclosure on page F-95 of Amendment No. 4.
Alliance Pharmaceutical Solutions, LLC
Independent Auditors’ Report, page F-113
4. Please have your auditor specify the period(s) covered by each financial statement identified in the report and the period(s) to which the opinion applies. Refer to paragraph 8c of AS 3101.
Response: In response the Staff’s comment, the Company’s auditor has revised the applicable disclosure on page F-113 of Amendment No. 4.
* * *
Thank you for your review and consideration of the matters set forth in this Response and in Amendment No. 4. If you have any questions, please contact the undersigned at (414) 488-7333 or KBechen@dykema.com.
Sincerely,
Dykema
Gossett PLLC
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filename1.htm
Dykema
Gossett PLLC
111
E. Kilbourn Ave.
Suite
1050
Milwaukee,
WI 53202
www.dykema.com
Tel:
414-488-7300
Kate
Bechen
Direct
Dial: (414) 488-7333
Email:
KBechen@dykema.com
November
5, 2024
U.S.
Securities and Exchange Commission
Division
of Corporate Finance
Office
of Trade & Services
100
F Street, N.E.
Washington,
D.C. 20549
Attention:
Rucha Pandit
Re:
Wellgistics
Health, Inc.
Amendment
No. 3 to Registration Statement on Form S-1
Filed
October 21, 2024
File
No. 333-280945
Dear
Ms. Pandit:
This
response letter (this “Response”) is submitted on behalf of Wellgistics Health, Inc. (the “Company”)
in response to the comments that the Company received from the staff of the Division of Corporation Finance (the “Staff”)
of the U.S. Securities and Exchange Commission (the “SEC”) in a letter addressed to Mr. Canning, dated November 4,
2024 (the “Comment Letter”), with respect to the Company’s Amendment No. 3 to Registration Statement on Form
S-1 (the “Registration Statement”), filed with the SEC on October 21, 2024. The Company is concurrently submitting
a fourth amendment to the Registration Statement (“Amendment No. 4”), which reflects the changes discussed in this
Response that the Company made to address the Staff’s comments.
For
reference purposes, each of the Staff’s numbered comments from the Comment Letter is set forth in bold text below, followed by
the Company’s response to each comment. All capitalized terms used but not defined in this Response have the meanings ascribed
to them in Amendment No. 4. Unless noted otherwise, any references to prior comments are to comments in the Staff’s October 15,
2024 letter.
The
responses below are based on information provided to Dykema Gossett PLLC by the Company.
Amendment
No. 3 to Registration Statement on Form S-1
Capitalization,
page 44
1.
Please
explain why there are differences in cash and accumulated deficit amounts in the Pro Forma column as compared to page 49.
Response:
In response the Staff’s comment, the Company has revised the applicable disclosure on page 44 of Amendment No. 4 to correct
the discrepancy.
California
| Illinois | Michigan | Minnesota | Texas | Washington, D.C. | Wisconsin
U.S.
Securities and Exchange Commission
Division
of Corporate Finance
November
5, 2024
Page
2
Danam
Health, Inc.
Statement
of Operations, page F-4
2.
Please
provide us your calculation of net loss per common share.
Response:
In response the Staff’s comment, the Company has revised the applicable disclosure on page F-4 of Amendment No. 4.
Community
Specialty Pharmacy, LLC
Independent
Auditors’ Report, page F-95
3.
Please
have your auditor specify the period(s) covered by each financial statement identified in the report and the period(s) to which the
opinion applies. Refer to paragraph 8c of AS 3101.
Response:
In response the Staff’s comment, the Company’s auditor has revised the applicable disclosure on page F-95 of Amendment
No. 4.
Alliance
Pharmaceutical Solutions, LLC
Independent
Auditors’ Report, page F-113
4.
Please
have your auditor specify the period(s) covered by each financial statement identified in the report and the period(s) to which the
opinion applies. Refer to paragraph 8c of AS 3101.
Response:
In response the Staff’s comment, the Company’s auditor has revised the applicable disclosure on page F-113 of Amendment
No. 4.
*
* *
Thank
you for your review and consideration of the matters set forth in this Response and in Amendment No. 4. If you have any questions, please
contact the undersigned at (414) 488-7333 or KBechen@dykema.com.
Sincerely,
Dykema
Gossett PLLC
/s/
Kate Bechen
Kate
Bechen, Esq.
cc:
Tim
Canning
Chief
Executive Officer
Wellgistics
Health, Inc.