SecProbe.io

CORRESP
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 filename1.htm

 INTELLINETICS,
INC.

 2190
Dividend Dr.

 Columbus,
Ohio 43228

 April
18, 2025

 Via
EDGAR

 Securities
and Exchange Commission

 Division
of Corporation Finance

 100
F Street, NE

 Washington,
D.C. 20549

 Attention:
Matthew Crispino

 Re:
 Intellinetics,
 Inc.:

 Registration
 Statement on Form S-3

 File
 No. 333-286586

 Acceleration
 Request

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Intellinetics, Inc. (the " Registrant ") hereby
requests acceleration of the effective date of the above-captioned Registration Statement to Tuesday, April 22, 2025 at 10:00 a.m., Eastern
time, or as soon thereafter as practicable.

 In
connection with this acceleration request, the Registrant hereby acknowledges that:

 ●
 should
 the Securities and Exchange Commission (the " Commission ") or the staff, acting pursuant to delegated authority,
 declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 ●
 the
 action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
 the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 ●
 the
 Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
 or any person under the federal securities laws of the United States.

 Please
contact Erin C. Herbst of Kegler, Brown, Hill & Ritter Co., L.P.A., counsel to the Registrant, at (614) 462-5420 as soon as the Registration
Statement has been declared effective.

 Very
 truly yours,

 INTELLINETICS,
 INC.

 By:
 /s/
 James F. DeSocio

 James
 F. DeSocio, President & CEO

 cc:
 Erin
 C. Herbst, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 17, 2025

James F. DeSocio
President and Chief Executive Officer
Intellinetics, Inc.
2190 Dividend Drive
Columbus, Ohio 43228

 Re: Intellinetics, Inc.
 Registration Statement on Form S-3
 Filed April 16, 2025
 File No. 333-286586
Dear James F. DeSocio:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Matthew Crispino at 202-551-3456 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
</TEXT>
</DOCUMENT>

CORRESP
1
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INTELLINETICS,
INC.

2190
Dividend Dr.

Columbus,
Ohio 43228

June
23, 2022

Via
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
D.C. 20549

    Attention:

    Anna
    Abramson, Staff Attorney

    Joshua
Shainess, Legal Branch Chief

    Re:
    Intellinetics,
    Inc.:

    Registration
    Statement on Form S-1

    File
    No. 333-264981

    Acceleration
    Request

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Intellinetics, Inc. (the “Registrant”) hereby
requests acceleration of the effective date of the above-captioned Registration Statement to Friday, June 24, 2022 at 4:00 p.m., Eastern
time, or as soon thereafter as practicable.

In
connection with this acceleration request, the Registrant hereby acknowledges that:

    ●
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ●
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
    the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
    or any person under the federal securities laws of the United States.

Please
contact Erin C. Herbst of Kegler, Brown, Hill & Ritter Co., L.P.A., counsel to the Registrant, at (614) 462-5420 as soon as the Registration
Statement has been declared effective.

    Very
    truly yours,

    INTELLINETICS,
    INC.

    By:
    /s/
    James F. DeSocio

    James
    F. DeSocio, President & CEO

    cc:
    Erin
    C. Herbst, Esq.

CORRESP
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Kegler,
Brown, Hill & Ritter Co., L.P.A.

65
E. State Street, Suite 1800

Columbus,
OH 43215

June
8, 2022

Intellinetics,
Inc.

Registration
of Form S-1 Filed May 16, 2022

File
No. 333-264981

Ms.
Anna Abramson

Division
of Corporation Finance – Office of Technology

Securities
and Exchange Commission

450
Fifth Street, N.W.

Washington,
D.C. 20549

Dear
Ms. Abramson:

We
note the receipt by Intellinetics, Inc. (the “Company”), a Nevada corporation, of the comment letter (the “Comment
Letter”) dated May 25, 2022 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
regarding the above-referenced Form S-1 (the “Form S-1”). On behalf of the Company, we hereby provide the responses set forth
below to the comments in the Comment Letter.

To
assist the Staff review, we have included the text of the Staff’s comments below in bold type.

Recent
Developments, page 3

    1.
    We
    note that you acquired Yellow Folder, LLC on April 1, 2022. Please provide the financial statements and pro forma financial information
    for Yellow Folder pursuant to Rule 3-05 and Article 11 of Regulation S-X. If you do not believe this information is required, please
    provide us with an analysis that includes the significance computations set forth in Rule 1-02(w) of Regulation S-X to support your
    conclusions.

The
Company plans to amend the Form S-1 to incorporate the financial statements and pro forma financial information for Yellow Folder pursuant
to Rule 3-05 and Article 11 of Regulation S-X, upon the completion and filing of those materials by June 15, 2022, as required. Please
note that by letter received from Jaime G. John, Associate Chief Accountant, on April 21, 2022, the Staff has indicated that it will
not object to the omission of the financial statements of Yellow Folder, LLC for the year ended December 31, 2020.

    2.
    We
    note your assertion on page F-46 that certain information about the Yellow Folder acquisition, including pro forma financial information,
    will be included in the Company’s Quarterly Report on Form 10-Q for the quarter ended June 30, 2022. In your response letter,
    please tell us the basis for this assertion and how such disclosure will comply with the timing requirements of Rule 3-05 of Regulation
    S-X.

The
Company will clarify this language upon amendment of the Form S-1 to indicate that 1) financial statements and pro forma financial statements
for Yellow Folder, LLC, for the year ended December 31, 2021 and the three months ended March 31, 2022, will be included in the
Form S-1 as amended and 2) financial statements reflecting the combined operations of Intellinetics and the assets of Yellow Folder,
LLC for the period following the acquisition on April 1, 2022 will be available in the Company’s Quarterly Report on Form 10-Q
for the quarter ended June 30, 2022.

Exhibit
Index, page II-7

    3.
    Please
    revise counsel’s legality opinion to remove the assumption that “the Company has sufficient shares of its authorized
    common stock available.” This assumption appears to be overly broad. Refer to Section II.B.3.a. of Staff Legal Bulletin 19
    for guidance.

The
Company’s Nevada counsel plans to omit the quoted language above and include the following:

“The
Placement Agent Warrant Shares, issuable upon the exercise of the Placement Agent Warrants, will be duly authorized, validly issued,
fully paid and non-assessable, so long as the Placement Agent Warrant Shares are issued pursuant to the terms of the Placement Agent
Warrants, and at the time of issuance, the certificates representing the Placement Agent Warrant Shares conform to the specimen thereof
examined by us and have been properly executed and delivered in accordance with Nevada law.”

*
*      *

The
Company would appreciate receiving any further questions or comments that the Staff may have regarding this letter or the Form S-1 at
the Staff’s earliest convenience. Please feel free to contact the undersigned at (614) 462-5420 or eherbst@keglerbrown.com.

    Sincerely,

    /s/
                                            Erin C. Herbst

    Erin
    C. Herbst

    cc:
    Intellinetics,
    Inc.

    Joseph
    D. Spain

United States securities and exchange commission logo
May 25, 2022
Joseph D. Spain
Chief Financial Officer
Intellinetics, Inc.
2190 Dividend Drive
Columbus, Ohio 43228
Re:Intellinetics, Inc.
Registration Statement on Form S-1
Filed May 16, 2022
File No. 333-264981
Dear Mr. Spain:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed May 16, 2022
Prospectus Summary
Recent Developments, page 3
1.We note that you acquired Yellow Folder, LLC on April 1, 2022.  Please provide the
financial statements and pro forma financial information for Yellow Folder pursuant to
Rule 3-05 and Article 11 of Regulation S-X.  If you do not believe this information is
required, please provide us with an analysis that includes the significance computations
set forth in Rule 1-02(w) of Regulation S-X to support your conclusions.
2.We note your assertion on page F-46 that certain information about the Yellow Folder
acquisition, including pro forma financial information, will be included in the Company’s
Quarterly Report on Form 10-Q for the quarter ended June 30, 2022.  In your response

 FirstName LastNameJoseph D. Spain
 Comapany NameIntellinetics, Inc.
 May 25, 2022 Page 2
 FirstName LastName
Joseph D. Spain
Intellinetics, Inc.
May 25, 2022
Page 2
letter, please tell us the basis for this assertion and how such disclosure will comply with
the timing requirements of Rule 3-05 of Regulation S-X.
Exhibit Index, page II-7
3.Please revise counsel's legality opinion to remove the assumption that "the Company has
sufficient shares of its authorized common stock available."  This assumption appears to
be overly broad.  Refer to Section II.B.3.a. of Staff Legal Bulletin 19 for guidance.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Anna Abramson, Staff Attorney, at (202) 551-4969 or Joshua Shainess,
Legal Branch Chief, at (202) 551-7951 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Erin C. Herbst

United States securities and exchange commission logo
May 12, 2020
James DeSocio
Chief Executive Officer
Intellinetics, Inc.
2190 Dividend Drive
Columbus, Ohio 43228
Re:Intellinetics, Inc.
Information Statement on Schedule 14C
Filed March 17, 2020
File No. 000-31671
Dear Mr. DeSocio:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Erin C. Herbst, Esq.

CORRESP
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INTELLINETICS,
INC.

2190
Dividend Dr.

Columbus,
Ohio 43228

May
12, 2020

Via
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
D.C. 20549

Attention:
Barbara C. Jacobs, Assistant Director

    Re:
    Intellinetics,
    Inc.:

    Registration
    Statement on Form S-1

    File
    No. 333-237721

    Acceleration
    Request

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Intellinetics, Inc. (the “Registrant”)
hereby requests acceleration of the effective date of the above-captioned Registration Statement to Wednesday, May 13, 2020
at 9:00 a.m., Eastern time, or as soon thereafter as practicable.

In
connection with this acceleration request, the Registrant hereby acknowledges that:

    ●
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ●
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
    relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
    the Commission or any person under the federal securities laws of the United States.

Please
contact Erin C. Herbst of Kegler, Brown, Hill & Ritter Co., L.P.A., counsel to the Registrant, at (614) 462-5420 as soon as
the Registration Statement has been declared effective.

    Very
    truly yours,

    INTELLINETICS,
    INC.

    By:
    /s/
    James F. DeSocio

    James
    F. DeSocio, President & CEO

    cc:
    Erin
    C. Herbst, Esq.

March 26, 2020
James DeSocio
Chief Executive Officer
Intellinetics, Inc.
2190 Dividend Drive
Columbus, Ohio 43228
Re:Intellinetics, Inc.
Information Statement on Schedule 14C
Filed March 17, 2020
File No. 000-31671
Dear Mr. DeSocio:
            We have reviewed your filing 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.
Information Statement on Schedule 14C
Approval of an Amendment to our Articles of Incorporation...
Reasons for the Reverse Split and Charter Amendments
1.We note your statement that the reverse split and charter amendments were necessary to
effectuate the acquisition of Graphic Sciences, Inc.  Therefore, it appears that you must
provide the disclosures required by Item 14 of Schedule 14A regarding the transaction.
Refer to Note A of Schedule 14A as well as Item 1 of Schedule 14C, which incorporates
the disclosure requirements of Schedule 14A.  Please revise to provide all such
information or, alternatively, explain why you believe such disclosure is not required.
            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 Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in his absence,

 FirstName LastNameJames DeSocio
 Comapany NameIntellinetics, Inc.
 March 26, 2020 Page 2
 FirstName LastName
James DeSocio
Intellinetics, Inc.
March 26, 2020
Page 2
Jan Woo, Legal Branch Chief, at (202) 551-3453, with any questions.  If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Erin C. Herbst, Esq.

CORRESP
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INTELLINETICS,
INC.

2190
Dividend Dr.

Columbus,
Ohio 43228

February
7, 2018

Via
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
D.C. 20549

Attention:
Barbara C. Jacobs, Assistant Director

    Re:
    Intellinetics,
    Inc.:

    Registration
    Statement on Form S-1

    File
    No. 333-222765

    Acceleration
    Request

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Intellinetics, Inc. (the “Registrant”)
hereby requests acceleration of the effective date of the above-captioned Registration Statement to Thursday, February 8, 2018
at 9:00 a.m., Eastern time, or as soon thereafter as practicable.

In
connection with this acceleration request, the Registrant hereby acknowledges that:

    ●
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ●
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
    relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
    the Commission or any person under the federal securities laws of the United States.

Please
contact Erin C. Herbst of Kegler, Brown, Hill & Ritter Co., L.P.A., counsel to the Registrant, at (614) 462-5420 as soon as
the Registration Statement has been declared effective.

    Very
    truly yours,

    INTELLINETICS,
    INC.

    By:

    /s/
    James F. DeSocio

    James
    F. DeSocio, President & CEO

    cc:
    Erin
    C. Herbst, Esq.

Mail Stop 4561

February 1, 2018

James F. DeSocio
Chief Executive Officer
Intellinetics, Inc.
2190 Dividend Drive
Columbus, Ohio 43228

Re: Intellinetics, Inc.
  Registration Statement on Form S-1
Filed  January 29, 2018
  File No.  333-222765

Dear Mr. DeSocio :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rule 461 regarding requests for acceleration.  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 st aff.

You may contact Jeff Kauten, Attorney -Advisor, at (202) 551 -3447, or in his absence, me at
(202) 551 -3453, with any questions.   If you require further assistance, please contact Barbara C.
Jacobs, Assistant Director, at (202) 551 -3730.

Sincerely,

/s/ Jan Woo

Jan Woo
Legal Branch Chief
Office of Information Technologies
and Services

cc:  Erin C. Herbst, Esq.
Kegler Brown Hill & Ritter Co., L.P.A.

CORRESP
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INTELLINETICS, INC.

2190 Dividend Dr.

Columbus, Ohio 43228

May 2, 2016

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Barbara C. Jacobs, Assistant Director

    Re:
    Intellinetics, Inc.:

    Registration Statement on Form S-1

    File No. 333-210484

    Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the
Securities Act of 1933, as amended, Intellinetics, Inc. (the “Registrant”) hereby requests acceleration of the
effective date of the above-captioned Registration Statement to Thursday, May 5, 2016 at 9:00 a.m., Eastern time, or as soon thereafter
as practicable.

In connection with this acceleration request,
the Registrant hereby acknowledges that:

 · should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 · the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does
not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 · the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

Please contact Erin C. Herbst of Kegler,
Brown, Hill & Ritter Co., L.P.A., counsel to the Registrant, at (614) 462-5420 as soon as the Registration Statement has been
declared effective.

    Very truly yours,

    INTELLINETICS, INC.

    By:
    /s/ Matthew L. Chretien

    Matthew L. Chretien, President & CEO

 cc: Erin C. Herbst, Esq.

Mail Stop 4561
April 26, 2016

Matthew L. Chretien
President and Chief Executive  Officer
Intellinetics , Inc.
2190 Dividend Drive
Columbus, OH 43228

Re: Intellinetics, Inc.
  Registration Statement on Form S-1
Filed  March 30, 2016
  File No.  333-210484

Dear Mr. Chretien :

This is to advise you that we have not  reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rule 461 regard ing requests for  acceleration .  We will consider a written
request for acceleration of the effective date of the registration statement as confirmation of the
fact that those requesting acceleration are aware of their respective responsibilities under the

Matthew L. Chretien
Intellinetics , Inc.
April 26, 2016
Page 2

 Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please contact Gabriel Eckstein at (202) 551 -3286 with any questions.

Sincerely,

 /s/ Barbara C. Jacobs

Barbara C. Jacobs
Assistant Director
Office of Information
        Technologies and Services

cc: Erin C. Herbst , Esq.
 Kegler Brown Hill & Ritter Co., L.P.A.