Gary A. Miller 215.851.8472 gmiller@eckertseamans.com |
April 25, 2019
Securities and Exchange Commission
Division of Corporation Finance
Office of Healthcare & Insurance
100 S Street, NE
Washington, DC 20549-0213
Attn: Keira Nakada
Attn: Sharon Blume
Re: Generex Biotechnology Corp.
Form 10-K for the Fiscal Year Ended July 31, 2018
Filed October 26, 2018
Form 8-K/A Dated October 3, 2018
Filed December 19, 2018
File № 000-25169
Mses. Nakada and Blume:
This is a supplemental response to the Staff’s first comment contained in your correspondence dated 1 March 2019.
Please find the issuer’s supplemental response below, restating the Commission’s comments in bold, and the company’s response in plain text.
| 1. | Report of Independent Accountants, page 3 - We note your auditor’s reference to a predecessor auditor for the fiscal year ended December 31, 2016. Please provide the signed audit report of the predecessor auditor referenced therein as required under Article 2 of Regulation S-X or tell us why such report is not required. If you are unable to obtain a reissued audit report, you must engage another accountant to reaudit the financial statements. |
Answer
On April 24, 2019, Generex submitted to the office of the Chief Accountant, Division of Corporate Finance, a request for waiver of the requirement to file the audited financial statements of the business acquired for the fiscal year ended December 31, 2016. We will submit a subsequent response to this comment promptly upon receiving a final disposition of that request.
Thank you for your attention and patience.
/s/ Gary A. Miller
Sincerely yours,
Gary A. Miller
GAM:ncd
Cc: Joseph Moscato, Chief Executive Officer
Mark Corrao, Chief Financial Officer
Marshal Shichtman, Esq.