0001654954-21-001578.txt : 20210315 0001654954-21-001578.hdr.sgml : 20210315 20210212134340 ACCESSION NUMBER: 0001654954-21-001578 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210212 FILER: COMPANY DATA: COMPANY CONFORMED NAME: IMAGEWARE SYSTEMS INC CENTRAL INDEX KEY: 0000941685 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 330224167 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11440 W. BERNARDO COURT STREET 2: SUITE 300 CITY: SAN DIEGO STATE: CA ZIP: 92127 BUSINESS PHONE: 8586738600 MAIL ADDRESS: STREET 1: 11440 W. BERNARDO COURT STREET 2: SUITE 300 CITY: SAN DIEGO STATE: CA ZIP: 92127 FORMER COMPANY: FORMER CONFORMED NAME: IMAGEWARE SOFTWARE INC DATE OF NAME CHANGE: 19991123 CORRESP 1 filename1.htm Blueprint
 
 
  
February 12, 2021
 
VIA EDGAR
 
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
 
RE:
ImageWare Systems, Inc.
 
Registration Statement on Form S-1
 
(File No. 333-251563)
 
Ladies and Gentlemen:
 
ImageWare Systems, Inc. (the “Company”) hereby requests acceleration of the effectiveness of the Registration Statement on Form S-1 (File No. 333-251563) (the “Registration Statement”) to 5:00 PM, Washington D.C. time, on February 12, 2021, or as soon as is practicable thereafter. The undersigned confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities registered pursuant to the aforementioned Registration Statement.
 
The Company acknowledges that the adequacy and accuracy of the disclosure in the Registration Statement is the responsibility of the Company. The Company further acknowledges that:
 
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should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
 
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the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
 
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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.
 
Upon grant of our request to accelerate effectiveness, we would appreciate your communicating with the Company’s counsel, Daniel Rumsey, via telephone at (619) 272-7062, to confirm the exact time at which the Registration Statement was declared effective.

 
 
Very truly yours,
 
IMAGEWARE SYSTEMS, INC.
 
/s/ Kristin Taylor
Kristin Taylor
President and Chief Executive Officer
 
 
cc:          Daniel Rumsey
Managing Director
Disclosure Law Group, a Professional Corporation